Home Health Articles and Information


Oct 9, 2019 8:16:00 AM / by Kristi Bajer, BSN, RN, COS-C

Should Home Health Take Notice of Therapy Carnage in PDPM?

At only 8 days in, PDPM seems to be making a therapy impact in skilled nursing facilities.  Opinions vary widely, with some just plain mad.  The comments below are in response to an online article about noticeable staff changes already happening in the wake of PDPM…..

      “It's been hard seeing our therapy staff of 35+ in a large campus go down to less than 15.”

     “Sadly, I'm now joining the ranks of the unemployed along with 9 other therapists in my facility.”

     “Not only are patients receiving less therapy per day, but our documentation demand has increased          and remaining therapists are all limited to 6 hours…”

     “If these providers were providing skilled services ethically all along, then they should need                             absolutely no staffing changes."

   “You all did this to yourselves. You had the chance to change things years ago by standing up to these      companies and stop the insane Medicare Fraud, but you choose not to, now you're gonna pay for it.”

    “I was a PTA for over 30 years before I threw in the towel 4 years ago because I did not want to go              threw[sic] another PPS. PPS, say hello to PDPM...”


Therapy over-utilization has been a top trigger of audit activity for years.  Under the PDGM payment model, it will switch from a revenue center to a cost center.  Instead of auditing therapy activity, CMS is just going to stop paying for therapy outside of the OASIS reimbursement. Should home health be worried? Yes…and No.  Providers who have kept utilization in line with the national averages should not notice a big payment change heading into the new model.

The current CASPER data from the Agency Patient Related Characteristics Report lists the average therapy per episode at between 7-8 visits.  Some providers with historically high therapy utilization, struggle with OASIS accuracy and the resulting decrease in reimbursement.  Using therapy has been a strategy for these providers to continue making adequate margins.  If this describes your agency, below are a few strategies to help your PDGM therapy transition;

  • Increase OASIS accuracy by providing training in OASIS
  • Give your quality assurance team the power to hold clinicians accountable for accuracy- consider “Live interactive QA” during the OASIS visit.
  • Use guidelines for therapy utilization based on the patient’s functional acuity from the OASIS- not solely the recommendations of the therapists
  • Give your administrator/director the power to hold therapists accountable
  • Pull your CASPER report and see what your average therapy utilization numbers are today
Are you needing help to ensure success in PDGM?  OperaCare’s compliance and quality assurance system will prepare your agency for an easy transition.

Tags: PDGM, Therapy, Home Health

Kristi Bajer, BSN, RN, COS-C

Written by Kristi Bajer, BSN, RN, COS-C

Kristi Bajer BSN, RN, COS-C, brings over 10 years of real world experience as a clinician, director, and administrator in home health. She is a firm believer in diagnosis driven evidence-based care in home health. Currently, she assists agencies with external chart audits and Medicare appeals, as well as providing training and coaching on OperaCare implementation and building QAPI programs using data to drive success and protect agencies from government audits.