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Skilled Maintenance Therapy: Meeting Your Patient's Needs

October 09, 2019
Documentation, Billing, & Coding By Deborah Alexander, Director

Is your practice treating more complex Medicare patients who may be at risk of declines in function or even hospitalization? These patients may be appropriate for “skilled maintenance therapy” under the Medicare Benefit Rules. In January of 2014, the Centers for Medicare and Medicaid Services (CMS) offered clarifications to the Medicare Benefit Policy Manual based upon the Jimmo vs. Sebilius settlement. This settlement reiterated CMS’ position that skilled therapy services are covered services, even in situations where no improvement is expected, but the services are to prevent a decline or deterioration in the patient’s condition.  


Senior man stretching with his therapist in fitness studio-1


The settlement required CMS to clarify their policies on “skilled maintenance therapy” including the documentation requirements and expanding upon the examples. If your practice is looking to start providing “skilled maintenance therapy,” it is wise to know the rules with use of assistants, as it varies by setting. It is also imperative the documentation requirements be met to support and distinguish the care is switching to a skilled maintenance program vs. rehabilitative program. 

CMS released the Frequently Asked Questions (FAQs) Regarding Jimmo Settlement Agreement sheet that answer common questions such as “If a patient is not improving or is not expected to return to his or her prior level of function from skilled nursing or therapy, does Medicare coverage for skilled nursing or skilled therapy services stop unless the patient deteriorates?” and “Can a patient receive therapy services from multiple disciplines with differing goals for restoration and maintenance?”.

For more information on skilled maintenance therapy and the Jimmo vs. Sebilius settlement, read this article from our “[Blog Series] Making Sense of Medical Necessity for Therapy.”

LW Consulting, Inc. can assist but reviewing 2 -3 complex patients being considered for a “skilled maintenance program” or who are already on a program. Our consultants can provide feedback on the documentation to best support the skilled need. We have to keep in mind Medicare makes if quite clear that merely having services provided by a therapist does not constitute skilled needs. Our documents must support our unique skills.


If you are interested in learning more or having several charts reviewed, contact Deborah Alexander at 717-213-3122 or email

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