Home Health Industry: CMS Documentation Proposal Needs Work

A rule proposed by CMS that seeks to make documenting therapy care for patients easier has not been well-recieved by home health professionals as they believe the rule’s less flexible parameters will actually make documentation more difficult.

The rule proposes a change in the way home care patients receiving therapy are evaluated by qualified therapists, and in addition to making the process easier, seeks to address concerns regarding unnecessary therapy visits to home care patients, according to the proposal made public in July. 

CMS’ proposal would require therapists to report effectiveness of patients’ therapy program around the 13th and 19th visits. Because many patients receive treatment from more than one therapist, CMS would require the first evaluation be done during the 11th, 12th or 13th visit and the second evaluation to be done during visits 17, 18 or 19.


Current regulation states that the evaluations can be done on or before the 13th and 19th visits, but CMS believes the industry needs increased and more precise guidance when it comes to patient therapy, according to the proposed rule. 

In line with current regulation, the new proposal maintains that if progress is not or cannot be measured, CMS will cease coverage of therapy services, excluding extraneous situations where progress is not expected. 

The proposal has been available for comment since the beginning of the month and many home health agencies do not agree with its parameters, according to Inside CMS, a newsletter that offers analysis of legal developments affecting Medicare and Medicaid. 


Problems cited by home health agencies revolve around the decreased amount of flexibility and increased coordinating the rule imposes on home health employees. 

Maine’s Community Health & Nursing Services cites in their comment on the proposal that patients often cancel therapy appointments due to other serious illness, causing complicated scheduling and a potential inability to follow the strict guidelines CMS is proposing. 

“In practice to meet such a strict schedule would not be feasible for a number of reasons,” said Community Health & Nursing Services. “I believe agencies would respond by increasing frequency of visits and some of these may not be needed, visiting only to meet regulatory compliance.”

Comments on the proposal are open until Sept. 4. 

Read the full proposal here

Written by Erin Hegarty

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