CMS Opts to Allows OTs to Open Medicare Home Health Cases

Portrait of health visitor and a senior woman during home visit


AOTA pleased after long-term advocacy effort


A decision by the Centers for Medicare & Medicaid Services (CMS) to allow occupational therapists the ability to conduct initial and comprehensive assessments for Medicare home health cases is being celebrated by the American Occupational Therapy Association (AOTA).


CMS issued an order last month to temporarily suspend certain regulatory requirements through waivers under Section 1135 of the Social Security Act so that health care facilities can maximize their frontline medical staff during the COVID-19 national health emergency, including a key rule for occupational therapy.


“We are pleased that CMS has recognized occupational therapy’s vital role in home health and AOTA’s advocacy efforts on this topic,” said Sherry Keramidas, PhD, FASAE, CAE, Executive Director of AOTA. “Access to occupational therapy services is more important than ever as occupational therapy practitioners are helping clients to navigate COVID-19 related challenges of occupational deprivation, participation in daily living, using occupation to support mental wellness, and re-engaging in occupations while recovering from COVID-19.”


The CMS decision has a retroactive effective date of March 1, 2020, through the end of the emergency declaration. According to the CMS Fact Sheet, the waiver:

Allow[s] occupational therapists (OTs) to perform initial and comprehensive assessment for all patients. CMS is waiving the requirement that occupational therapists may only perform the initial and comprehensive assessment if occupational therapy is the service that establishes eligibility for the patient to be receiving home health care. This temporary blanket modification allows occupational therapists to perform the initial and comprehensive assessment for all patients receiving therapy services as part of the plan of care, to the extent permitted under state law, regardless of whether occupational therapy is the service that establishes eligibility. 


AOTA has advocated for years to make this a permanent reality in order to increase access to services for Medicare beneficiaries, increase efficiency, and support independent living without increasing costs. Occupational therapy has long been a valued component of home health care due to therapists’ expertise in identifying home safety issues, providing self-care training and modifications to promote independence in critical ADLs such as dressing and bathing, and in establishing routines to maximize a client’s ability to follow his or her plan of care.



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