CMS Proposed Rule Includes Permanent Flexibility for Occupational Therapists to Open Home Health Cases

07/01/2021

Following AOTA advocacy for expanding roles for the occupational therapy profession, the Centers for Medicare & Medicaid Services’ (CMS’) proposed home health prospective payment system (HH PPS) rule included provisions allowing occupational therapists to perform the initial and comprehensive assessments required to open Medicare home health therapy cases on a permanent basis beginning on January 1, 2022. Occupational therapists have been allowed to open such cases, but only during the COVID-19 public health emergency. The proposal would implement the Consolidated Appropriations Act of 2021 that was signed into law on December 27, 2020, which included the provisions of the Medicare Home Health Flexibility Act. AOTA long advocated for this change as a way to better recognize occupational therapy as an essential component of home health care and help identify and address patient need for occupational therapy services. This is especially critical under the Patient-Driven Groupings Model that changed the Medicare Part A home health payment model on January 1, 2020. AOTA is grateful for the work of our legislative champions and member advocacy that pushed this over the finish line.

The proposed rule would update the home health conditions of participation to allow an occupational therapist to conduct the initial assessment visit and complete the comprehensive assessment under the Medicare program when occupational therapy is on the home health plan of care with either physical therapy or speech therapy, and skilled nursing services are not initially on the plan of care. In the proposed rule, CMS recognizes that this change will allow the most appropriate rehabilitation skilled professional to make the initial assessment visit. The proposed rule would not alter Medicare’s criteria for establishing eligibility for the home health benefit, but it is an important step in eliminating unnecessary barriers to occupational therapy services in the home. AOTA will continue advocating for the value of occupational therapy services in home health and will be implementing a micro-credential in fall 2021 as part of a home care professional certificate for occupational therapists interested in learning more about opening cases and conducting home health assessments.

The HH PPS proposed rule is scheduled to be published in the Federal Register on July 7, 2021, and comments are due to CMS by August 27, 2021. AOTA staff is analyzing additional provisions of the proposed rule and will submit written comments. Read the CMS Fact Sheet for an overview of the proposed rule.

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