The Centers for Medicare & Medicaid Services (CMS) is waiving the requirements that rehabilitation skilled professionals may only perform the initial and comprehensive assessment when only therapy services are ordered. This is based off of an update from May 11, 2020 to the 1135 waiver. This helps these professionals run as efficiently as possible during the COVID-19 public health emergency.

In April, CMS issued a waiver allowing occupational therapists to perform the initial and comprehensive assessment for all patients that receive therapy services as a part of their plan of care regardless if occupational therapy is the service that establishes eligibility.

CMS also recently implemented CARES Act regulations for another permanent home health change. This change is that non-physician practitioners can order home health services and are certified eligible for home health.

The new temporary blanket modification allows any rehabilitation skilled professionals to perform the initial and comprehensive assessment for all patients receiving therapy services as a part of the plan of care regardless of whether or not the service establishes eligibility for the patient to be receiving home care. This blanket waiver covers occupational therapists, speech-language pathologists, and physical therapists. The goal of this blanket waiver is to decrease patient wait times for the initiation of home health services. The waiver does state therapists still may not perform assessments in nursing-only cases.

CMS has the expectation that home health agencies match the appropriate discipline that performs the assessment to the needs of the patient to the greatest extent possible. It is also expected that therapists will act within their state’s scope of practice laws and will access another healthcare professional to complete the sections of the assessment that are beyond their scope of practice.

To learn more about CMS’ Blanket Waivers during the COVID-19 global pandemic, you can visit: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf