NCAL Connection (4/16, Ciolek)
On April 3, the Centers for Medicare and Medicaid Services (CMS) issued clarifications to the State Operations Manual (SOM) titled “Clarification of Requirements for Off-Premises Activities and Approval of Extension Locations for Providers of Outpatient Physical Therapy and Speech-Language Pathology Services.”
These revisions provide clarification to guidance for the two-person on duty requirement, approval of extension locations, and permissible off-premises activities, with a particular emphasis on those Medicare therapy services furnished by rehabilitation agencies within an assisted living facility (ALF). While these policies do not apply directly to NCAL member facilities, they may indirectly impact ALF operations and most importantly, the rehabilitation service delivery options available to NCAL member residents.
Below is a brief summary of the three key policy clarifications related to ALFs. These policy clarifications are effective immediately. If you have questions or comments, please contact Dan Ciolek, AHCA/NCAL Senior Director of Therapy Advocacy at firstname.lastname@example.org.
Two-Person on Duty Requirement
Any space leased, rented, or dedicated for the provision of rehabilitation agency services, including space within an ALF that is designated for therapy service, must meet the two person on duty requirement and become a separately certified rehabilitation agency or become approved as an extension location of a currently certified rehabilitation agency. Leased or rented space that is dedicated to therapy services must be […]