As of January 1, 2022, Occupational Therapists may permanently perform the Start-of-Care Comprehensive Assessment for therapy-only referrals. However, for a patient to be admitted into home health services for therapy-only, physical and/or speech therapy must also be ordered. Medicare home health rules continue to prohibit occupational therapy from being the sole qualifying skill for admission, as this has been a longstanding regulation.
The common issue agencies continue to question is when an Occupational Therapist can independently continue services without another skill continuing care. A clarification was made a few years ago that if physical therapy initiates the case, for instance, the occupational therapist can perform an evaluation and physical therapy would then be required to conduct at least one more visit for the occupational therapist to stand alone throughout the remainder of the patient’s episode. In essence, a qualifying skill initiates the services, occupational therapy performs an evaluation, another qualifying skill provides an additional visit, and then occupational therapy can work independently.
During the 2022 Final Rule, comments leading up to implementation in January 2022, CMS provided clarification on the process. They stated that the order of services is no longer a concern, and that when occupational therapy conducts the Start-of-Care assessment, they must ensure that there is a documented need for an additional qualifying skill. In other words, if occupational therapy performs the Start-of-Care assessment, there should be an established qualifying skilled need for another discipline documented during that assessment. Following the assessment, an evaluation visit by physical or speech therapy would be conducted, and after these evaluations, occupational therapy could work independently.
The ability for occupational therapy to conduct recertification assessments and continue in recertification episodes independently has always been in place, and this remains unchanged.
We would like to draw your attention to a recent therapy documentation blog that we published, Improving Home Health Therapy Documentation, which we highly recommend all therapists review. Additionally, if you require any further clarifications regarding occupational therapy or their regulatory allowance to conduct the Start-of-Care Comprehensive Assessment, please do not hesitate to contact us. We are here to assist and provide any necessary information you may need.
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