Is It Appropriate for Occupational Therapists to Perform the Initial Start of Care for Home Health?

Occupational therapy services are an important component to the overall assessment and functional outcomes associated with home health.  Medicare restricts occupational therapists from performing the initial comprehensive assessment (start of care) for home health. In skilled nursing facilities, long term care, and outpatient therapy settings, occupational therapists are permitted to perform the initial evaluation and be the only discipline ordered by a physician with patients who have Medicare as their primary insurance.  Home health is the only setting that prohibits occupational therapists from performing the initial comprehensive assessment when a patient has Medicare as their primary insurance.

The Conditions of Participation for Home Health (CoPs, 484.55), states that occupational therapists can conduct the initial comprehensive assessment on therapy-only patients for whom occupational therapy establishes eligibility.  However, the State Operations Manual (SOM) Appendix B: Guidance for Surveyors for Home Health Agencies restricts occupational therapy as being the initial qualifying service for home health.  Various payers, such as Medicaid, private pay, and multiple managed care providers, allow occupational therapy to establish the initial eligibility for home health.  The SOM Appendix B does allow occupational therapists to be the only discipline providing services when there is a continuing need, but only after an initial comprehensive assessment has been performed by a registered nurse, physical therapist, or speech-language pathologist. If occupational therapy is the only service that has a continuing qualified need, then they can perform Oasis assessments, such as resumption of care, transfer, recertification, or discharge.

Occupational therapists are skilled professionals trained at a graduate level and provide an array of skilled services, such as techniques and adaptations for safe toileting, bathing, dressing, feeding, wheelchair positioning, managing daily habits, and home safety issues.  Occupational therapists can be a valuable resource to conduct the initial comprehensive visit for home health.  The demand for nursing and therapy professionals is a concern nationwide for all health care settings.  By increasing the number of available clinicians to perform the initial comprehensive visit, this could decrease occurrences in the delay of care due to staffing challenges, address home safety issues earlier that warrant only occupational therapy services, and provide the appropriate indicated services to the patient immediately upon referral.

Agencies and consumers should not restrict patients from receiving an initial comprehensive visit from an occupational therapist if they are a non-Medicare beneficiary that allows occupational therapists to perform the initial comprehensive assessment.  The CoPs for home health haven’t revised the qualifications for who is qualified to perform an initial comprehensive assessment.  The SOM Appendix B: Guidance for Surveyors for Home Health Agencies has yet to release an updated version to reflect the final rule of the CoPs for HHA.  The operators of the SOM Appendix B have the opportunity to revise the interpretative guidelines to permit occupational therapy as an initial qualifying service. The final rule for the CoPs is scheduled to be effective on July 13th, 2017.  The SOM Appendix B needs to be revised to address the modifications in the CoPs and update any other areas to reflect the current healthcare needs. Home health appropriateness of services, quality of care, coordination of care, and staffing challenges could improve if the interpretative guidelines in the SOM Appendix B were revised to permit occupational therapy as an initial qualifying service for all payer sources.

Do you think the interpretative guidelines should be modified to allow occupational therapists to do the initial comprehensive assessment for home health?  Put your comments below.

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