Medicare personnel qualifications for therapists and home health agency compliance

Together with the updated Medicare Physician Fee Schedule Final Rule published in the Federal Register, November 27, 2007, the Center for Medicare and Medicaid Services (CMS) revised the personnel qualification standards for therapy services by amending Medicare Regulation 42 Code of Federal Regulations (CFR), Section 484.4. These new qualifications and grandfathering provisions applied to home health January 1, 2008 and will apply to all settings by December 31, 2009. As stated by CMS, these changes were necessary to have consistent standards for personnel providing therapy services in all settings, to correct outdated terminology related to relevant professional organizations, and to update the licensure, training, and education requirements for all therapists, whether trained in the United States or in a foreign setting. It is important for agencies to review the requirements now because some therapy staff may need the next year to fulfill certain educational and national examination requirements, depending on their state of practice, and to be considered qualified based on the grandfathering provisions.