by Darcey Trescone
Occupational therapy is a profession that has evolved and adapted to the current Medicare home health culture. According to Karen Vance, BSOT, and Senior Managing Consultant at BKD, LLP, "As an industry, we under-utilize the OT discipline and have lost sight of the value they offer in providing and coordinating the services that encourage patient independence." Vance has been involved with the American Occupational Therapy Association and an advocate for the Home Health Flexibility Act for years. As a well-known speaker at the annual AOTA conference, she has also worked closely with AOTA on policy issues.
According to Vance, because OT has been restricted in their activities under Medicare, the profession has also adapted to having less responsibility, "Honestly, some OT professionals are looking forward to having increased capabilities as part of the care team. They see these changes as a way to advance the profession, while others are upset and concerned that the Home Health Flexibility act will increase their workload."
On December 21, 2020, the Medicare Home Health Flexibility Act was passed by Congress, establishing a new rule allowing OT's to open Medicare home health therapy cases permanently, which goes into effect no later than January 1, 2022. Occupational therapists have been permitted to open Medicare home health cases temporarily since April 2020, when CMS issued an emergency rule related to the COVID-19 pandemic. However, this emergency rule will expire when the Public Health Emergency ends.
Our history and market evolutions have outlined the culture for OT to date, Vance explained to us. In the 1960s, it was determined under the home health benefit that licensed professionals could govern their practice. Unfortunately, in the 1960s, OT was not a licensed profession in all fifty states, and it took many years to achieve licensure nationwide. In 1998, new COPs and the Oasis documentation were put in place, again restricting the OT's ability to open Medicare home health therapy cases.
Over the years, the Payment reforms have contributed to the under-utilization of the OT discipline when delivering Medicare home health services. The theory and principles of Occupational Therapy have conflicted with payment models for many years, Vance explains further:
Under PDGM today, the reimbursement incentives no longer promote a high PT utilization, and agencies have demonstrated decreased PT utilization trends. PDGM also re-focuses the industry on outcome improvement and promoting patient independence through self-management of their disease process.
"The Home Health Flexibility act provides an opportunity for OT to stand up as a profession and demonstrate their value to the industry," Vance explained. "As a discipline that focuses on patient independence, the OT's role is to identify the disciplines required on the care team, educate the patient to manage their disease process, and ultimately improve the patient's independence level over a short period. A higher involvement of the OT discipline in Medicare home health cases will improve clinical and financial outcomes if utilized correctly within an agency."
Additionally, many US agencies are navigating through a nursing shortage that is not likely to improve. "There are not enough nurses to open Medicare home health patients, and the Home Health Flexibility act provides agencies more resources to open any therapy case. OT will finally be able to do an initial start and comprehensive assessment, which since 1998, when CMS put the COPs and Oasis documentation in place, they were unable to do."
CMS has a year to put the new permanent rule in place, allowing an OT to open Medicare home health therapy cases. The Pfizer and Moderna vaccines' current availability will ideally provide a light at the end of the pandemic tunnel, ending the Public Health Emergency. We can expect a period where OT can no longer open Medicare home health therapy cases until CMS establishes the new rule for OT under the Medicare Home Health Flexibility Act.
Karen Vance is a Managing Consultant with BKD Health Care Group since 2003, delivering clinical and operations consulting services to home care providers. She also provides reimbursement and compliance consulting services and helps home care providers establish and maintain quality management practices. With home care experience since 1981 as a provider, clinical and regulatory manager, Karen has presented home care seminars since 1988 for national, state and regional health care associations and industry media organizations.
Darcey Trescone, RN, BSN, is a Healthcare IS and Business Development Consultant in the Post-Acute Healthcare Market with a strong background working with both providers and vendors specific to Home Care and Hospice. She has worked as a home health nurse and held senior operational, product management and business development positions with various post-acute software firms, where her responsibilities included new and existing market penetration, customer retention and oversight of teams across the U.S., Canada and Australia. She can be reached at email@example.com.
©2020 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Home Care Technology: The Rowan Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. firstname.lastname@example.org