AAHSA – Frequently Asked Questions On RUGs IV (Therapy)

Frequently Asked Questions On RUGs IV. – FAQs:

• In Chapter 3 of the Resident Assessment Instrument (RAI) manual, CMS discusses concurrent therapy as no more than two (2) residents per “therapist or “therapist assistant.”  Where can I find a reference to this rule?

Answer: A reference to this new rule is available on the FY 2010 SNF PPS final rule (74 FR 40315ff). The limitation of concurrent therapy is to only two residents at a time, set to become effective upon the implementation of RUG-IV (i.e., as of FY 2011).

• Would therapist provided by “aides” be allowed to be counted in the total number of therapy minutes delivered to the resident?

Answer: No. Therapy aides are not equivalent to therapy assistants. Therapy assistants receive education specific to that discipline, either physical therapy or occupational therapy, while there are no standards for therapy aides. In chapter 15 of the Medicare Benefit Policy Manual, Pub. 100-2, (section 230) qualifications for therapists, assistants and aides are discussed. In addition, in chapter 3, section O of the Resident Assessment Instrument (RAI) manual, CMS states that therapy aides may not provide skilled services (pg. O-16).

Source: American Association of Homes and Services for the Aging http://www.aahsa.org