Occupational Therapist CoP Changes

Year 2022 is almost here and those of us in home health care must consider the Final Rule and changes which become effective on January 1, 2022.  One alteration to the Conditions of Participation is the allowance of an occupational therapist to perform the initial visit and comprehensive assessment.  This is a bit of a continuation of the Public Health Emergency waiver, however, there are some specific rules involved.  First of all, if the order for home health care services includes skilled nursing, an RN must perform the initial visit and comprehensive assessment.  OT may perform this visit and assessment only if OT is included in the orders along with another qualifying service–PT or ST–and there is no skilled nursing ordered.  At the time of initial visit, the OT has to determine if the patient meets eligibility for the home health benefit, including being homebound.  As long as another qualifying service has been ordered, the OT’s visit with performance of skilled care during that visit establishes the start of care date.  This change in regulation is to ensure patients receive care in a timely manner.  Merry Christmas to us!