CoP Changes for Occupational Therapists

Some changes to the home health Conditions of Participation (CoP) that were implemented during the COVID-19 public health emergency (PHE) have been made permanent in the 2022 home health final rule effective January 1st.

One of these changes is the blanket waiver that allows occupational therapists to conduct the initial home health assessment visit and complete the comprehensive assessment under the Medicare program. But this is only applicable when occupational therapy is on the home health plan of care with physical therapy and/or speech therapy, and skilled nursing services are not initially on the plan of care.

Further Guidance

  • The occupational therapist may perform initial visit and assessment ONLY if they are included in the orders, along with another qualifying service, such as physical therapy or speech therapy, and there is no skilled nursing ordered.
  • A registered nurse must perform the initial visit and comprehensive assessment if the order for home health care services includes skilled nursing.
  • At the time of the initial visit, the occupational therapist has to determine if the patient meets eligibility for the home health benefit, including being homebound.
  • The OT’s visit with the performance of skilled care during that visit establishes the start of care date as long as another qualifying service has been ordered.

Occupational Therapy LUPA Add-on Factor

The Centers for Medicare & Medicaid Services (CMS) is establishing a Low Utilization Payment Adjustment (LUPA) add-on factor since occupational therapists can now conduct the initial and comprehensive assessments. It is for calculating the LUPA add-on payment amount for the first skilled occupational therapy visit that occurs as the only period of care in LUPA periods, or the initial 30-day period of care in a sequence of adjacent 30-day periods of care.

However, at present, there is not enough data regarding the average excess of minutes for the first visit in LUPA periods when the initial and comprehensive assessments are conducted by occupational therapists. Therefore, CMS will utilize the physical therapy LUPA add-on factor as a proxy until CY 2022 data can establish a more accurate occupational therapy add-on factor for the LUPA add-on payment amounts.

Good Change and Keeping Up with It

The purpose of this change in regulation is to make sure that patient care is delivered in a timely manner. Along with other important updates from the 2022 home health final rule, agencies’ clinical teams and contractors should be on top of all changes to efficiently utilize staffing, maintain compliance, and optimize cash flow.

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