Q: Can a subcontractor physical therapist do a therapy start of care OASIS if they are the only modality in? Can a subcontractor physical therapist do the OASIS or recertification?
A: §484.14 (a) of the Home Health Conditions of Participation allow an agency to provide skilled, qualifying services under arrangement (contract) as long as the agency provides at least one of the qualifying services directly through agency employees. As a skilled and qualifying service under arrangement, a contract physical therapist has the ability to perform OASIS comprehensive assessments, as long as the primary agency manages and supervises those services. This includes assuring the therapist is competent to perform the comprehensive assessment. §484.14 (f) specifies the requirements necessary for personnel under per visit contracts, which include the necessity for contract staff to conform to all applicable agency policies, the responsibility of contract staff to participate in developing plans of care, the manner in which services will be controlled, coordinated, and evaluated by the agency, and the procedures for submitting clinical notes.
March 1st, 2010 at 2:17 pm
We read the first statement you made! If the agency has only contract physical therapy, can patients be admitted for therapy only? It seems confusing as we have therapy only cases, no nursing, and yet we do the admitt and oasis. You make it sound like there must be another qualifying service with our employee. Can you clarify????
March 1st, 2010 at 2:28 pm
Hi LuAnn,
I apologize for my statement not being completely clear. The agency as a whole has to offer at least one qualifying discipline directly by the agency (not under arrangement). It is not on a patient-by-patient basis. This means that an agency cannot offer all of its services under arrangement. I hope this clarifies your question.
Thanks for reading and for your comment!
Lu
March 2nd, 2010 at 5:00 pm
A point of clarification. If a physical therapist, or any other therapist for that matter, contracts with a home health agency to furnish a therapeutic service that individual is a contractor not a sub contractor. A subcontractor would be a therapist who is available via a contract with another organization. The contract for therapy services woudl be between the home health agency and the contracting entity not the physical therapist. This has implications for review of the contracting organization’s financial records by CMS or other authorized representative to examine the nature and extenct of costs incurred by the home health agency under the agreement.