Outpatient therapy provided in the home has long been an established and reimbursable service, as outlined by the Centers for Medicare & Medicaid Services (CMS). According to CMS (2025, Chapter 15, Sec. 220.1.4, pg. 156), therapy services are payable under the Physician Fee Schedule when furnished by:
- A provider to its outpatients in the patient’s home
- A provider to patients seen at the facility’s outpatient department
- A provider to inpatients of other institutions
- A supplier to patients in the office or in the patient’s home
(Note: Comprehensive Outpatient Rehabilitation Facility (CORF) regulations differ when it comes to therapy provided in the home.)
Outpatient therapy services delivered in the home are reimbursed at the same rate as services provided in outpatient clinics. However, travel expenses incurred by providers for visiting a patient’s home are not reimbursed (CMS, 2025, Chapter 15, Sec. 220.1.4, pg. 157).
Conditions for Coverage
To qualify for outpatient therapy services in the home, three conditions must be met (CMS, 2025, Chapter 15, Sec. 220.2, pg. 146–147):
- The individual requires (or required) therapy services.
- A plan of care has been established by a physician, non-physician practitioner (NPP), or the treating therapist, and is periodically reviewed by a physician or NPP (42 CFR 424.24(c), §220.1.2).
- The services are furnished while the individual is under the care of a physician (42 CFR 424.24(c), §220.1.1).
Skilled therapy may be required to:
- Improve a patient’s current condition
- Maintain functional abilities
- Prevent or slow further decline
(CMS, 2025, Chapter 15, Sec. 220.2, pg. 158)
Industry Shifts and Practice Trends
Since the implementation of PDPM (Patient-Driven Payment Model) and PDGM (Patient-Driven Groupings Model), outpatient therapy delivered in the home has seen significant growth. These payment model changes led to widespread layoffs in institutional settings, prompting many therapists to seek alternative practice models. In response, our Therapy Business Builder program launched in October 2019 to support therapists in starting their own mobile outpatient practices—many of whom have since found success in this model.
Key Considerations and Limitations
It is essential to understand that outpatient therapy in the home is not covered when a patient is receiving services under Home Health Medicare Part A. These two services cannot be billed simultaneously.
In an ideal scenario, a patient who is homebound and qualifies for Home Health under Medicare Part A should receive therapy and other services through this benefit, which does not require copays and offers a team-based approach—including nursing, therapy, home health aides, and more.
However, in practice, many Home Health agencies limit therapy services, dictating the number of visits based on business policy rather than clinical need. In some cases, clients are kept on Home Health services even after they are no longer homebound, which restricts access to outpatient therapy services they may benefit from.
Ideally, Home Health should serve as a transitional support system—bridging hospital or skilled nursing facility discharge with the goal of regaining independence. Once the patient no longer meets homebound criteria, they should be transitioned to outpatient therapy, which can be provided either in the home or in a clinic, depending on what best serves the client.
Utilization and Quality Concerns
According to CMS data (Healthcare Financial Management Association, 2024), the average number of visits per 30-day Home Health episode in 2023 was:
- Skilled Nursing: 3.86 visits
- Physical Therapy: 2.78 visits
- Occupational Therapy: 0.76 visits
- Speech-Language Pathology: 0.14 visits
- Medical Social Services: 0.05 visits
- Home Health Aide: 0.42 visits
These numbers reflect not only limited access to therapy services, but also raise concerns about quality of care. Therapists often report being pressured to keep sessions under one hour and complete documentation during the visit—conditions that compromise both treatment depth and therapeutic outcomes.
Following the implementation of the Patient-Driven Groupings Model (PDGM) in 2020, there have been significant shifts in how care is delivered. Even before PDGM was fully enacted, therapy thresholds were eliminated in 2019, triggering a steady decline in therapy utilization. By 2024, CMS (2023) reported that a larger proportion of Home Health episodes included only one to five therapy visits, and overall therapy use had decreased across all clinical groupings compared to pre-PDGM years (2018–2019).
Not only are the number of visits limited, but CMS data (2025) also reveals that the duration of these visits is often well under an hour. For non-first visits in non-LUPA episodes, the average duration is 41.54 minutes for skilled nursing (SN), 45.11 minutes for physical therapy (PT), 47.15 minutes for speech-language pathology (SLP), and 45.98 minutes for occupational therapy (OT).
These numbers simply do not align with the level of care individuals on Home Health should receive. For example, research on home safety assessments and modifications alone supports the need for two to three initial occupational therapy sessions, followed by a six-month booster session for optimal effectiveness and long-term outcomes (Norin et al., 2021; Fishpool & Bridge, 2012; McBride, Story, & Cason, 2023; S. Stark, personal communication, December 2024).
The Value of Mobile Outpatient Therapy
Many of our clients and their families have shared that mobile outpatient therapy services—provided under Medicare Part B—are vastly different in both quality and consistency compared to what they experienced under traditional Home Health services. Outpatient therapy provided in the home by physical and occupational therapists typically occurs two to three times per week, with frequency tapering as the patient progresses. When appropriate, maintenance therapy can also be continued to support long-term outcomes.
Across the U.S., high-quality mobile outpatient therapy has proven effective in helping individuals maintain independence, avoid assisted living or skilled nursing placements, and reduce hospitalizations. These benefits are further enhanced through collaboration with local healthcare providers and community resources.
Our own mobile outpatient practice – Home Therapy Solutions was the first in the country to be formally recognized as an Age-Friendly Therapy Practice, earning a Level 2 – Committed to Care Excellence designation in the spring of 2025. As part of the Age-Friendly Health System movement, we are committed to addressing the “4Ms” in all care delivery:
- What Matters to the individual
- Medication safety and optimization
- Mentation (cognitive health)
- Mobility and safe functional independence
It is simply not feasible for a therapy provider to meaningfully address these critical areas with the limited visit counts currently seen in Home Health.
In today’s fragmented healthcare system—marked by multiple care transitions, poor discharge planning, and ineffective communication—it’s no surprise that research shows older adults receive only about 50% of the care recommended (Fulmer et al., 2021) (Helwig, 2022) (Higashi et al., 2004) (United Health Foundation, 2023). The mobile outpatient model directly addresses these shortcomings by delivering consistent, personalized, and evidence-informed care in the home.
Not only are we improving outcomes, but we are also doing so cost-effectively—keeping individuals in their homes longer and reducing the overall burden on the healthcare system.
Advocacy and Awareness
We believe it is essential that clients receive the full range of benefits available to them through Medicare—including Home Health services—when medically appropriate. Equally important is ensuring that clients and caregivers are aware of their right to access outpatient therapy services under Medicare Part B, which often provides more intensive, consistent, and personalized care compared to traditional home health models.
With the right services in place, clients are better supported to maintain function, prevent rehospitalizations, and continue living safely and independently at home.
Unfortunately, we continue to encounter challenges in educating hospital and rehabilitation discharge planners. These professionals frequently limit their recommendations to Medicare Part A Home Health agencies listed on Care Compare, which are assigned Star Ratings. Because mobile outpatient therapy practices under Medicare Part B are not included in these directories or given Star Ratings, our services are often excluded from discharge planning conversations—even though we have consistently educated providers on the key differences between Home Health (Part A) and Mobile Outpatient Therapy (Part B).
For example, if you visit the Care Compare website and and search for Home Health providers, you will not find outpatient therapy practices that deliver care in the home under Part B.
To help bridge this gap, we’ve created a directory of home and community care therapy practices.
Many of the clinics in this directory provide mobile outpatient therapy services: https://nextlevelot.com/specialist-directory/
References
American Speech‑Language‑Hearing Association. (2024, July 3). CMS announces Medicare home health proposed payment rates and policies for 2025. https://www.asha.org/news/2024/cms-announces-medicare-home-health-proposed-payment-rates-and-policies-for-2025/
Centers for Medicare & Medicaid Services. (2023, November 13). Medicare Program; Calendar Year (CY) 2024 Home Health (HH) Prospective Payment System Rate Update; HH Quality Reporting Program Requirements; HH Value-Based Purchasing Expanded Model Requirements; Home Intravenous Immune Globulin Items and Services; Hospice Informal Dispute Resolution and Special Focus Program Requirements; Certain Requirements for Durable Medical Equipment Prosthetics and Orthotics Supplies; and Provider and Supplier Enrollment Requirements [Final rule]. Federal Register, 88(217), 77676–77880. https://www.federalregister.gov/documents/2023/11/13/2023-24455/medicare-program-calendar-year-cy-2024-home-health-hh-prospective-payment-system-rate-update-hh
Centers for Medicare & Medicaid Services. (2024, June 26). Calendar year (CY) 2025 Home Health Prospective Payment System proposed rule fact sheet (CMS‑1803‑P). U.S. Department of Health & Human Services. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2025-home-health-prospective-payment-system-proposed-rule-fact-sheet-cms-1803-p
Centers for Medicare & Medicaid Services. (2025, January 16). Medicare benefit policy manual (Publication No. 100‑02), Chapter 15: Covered medical and other health services (Rev. 13051). U.S. Department of Health & Human Services. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.pdf
Centers for Medicare & Medicaid Services. (2025, July 2). Medicare and Medicaid Programs; Calendar Year 2026 Home Health Prospective Payment System (HH PPS) Rate Update; Requirements for the HH Quality Reporting Program and the HH Value-Based Purchasing Expanded Model; Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Updates; DMEPOS Accreditation Requirements; Provider Enrollment; and Other Medicare and Medicaid Policies [Proposed rule]. Federal Register, 89(128), 29088–29168. https://www.federalregister.gov/documents/2025/07/11/C2-2025-12347/medicare-and-medicaid-programs-calendar-year-2026-home-health-prospective-payment-system-hh-pps-rate
Fishpool, J., & Bridge, C. (2012). Follow-up efficacy post environmental modifications: A guide for clinical practice (1st ed., 2nd printing, July 2014). Home Modification Information Clearinghouse, City Futures Research Centre, UNSW Australia. https://www.homemods.info
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Helwig, A. (2022, August 4). Six keystone improvements to address surge in older adults living longer. RTI Center for Health Care Advancement. https://healthcare.rti.org/insights/chronic-disease-healthcare-for-the-elderly#:~:text=In%20many%20ways%2C%20the%20current,many%20times%20more%20expensive%2C%20care.
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McBride, C., Story, S., & Cason, J. (2023). Development and validation of the protocol for administering telehealth home (PATH) assessments. International Journal of Telerehabilitation, 15(1), e6545. https://doi.org/10.5195/ijt.2023.6545
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Norin, L., Slaug, B., Haak, M., & Iwarsson, S. (2021). Housing adaptations and housing accessibility problems among older adults with long-standing spinal cord injury. British Journal of Occupational Therapy, 84(12), 765–774. https://doi.org/10.1177/0308022620979516
United Health Foundation. (2023). 2023 Senior report. America’s Health Rankings. https://www.americashealthrankings.org/learn/reports/2023-senior-report?utm_source=external&utm_medium=newsroomstory&utm_campaign=2023seniorreport&utm_content=report
Kara Welke, OTD, OTR/L, CLT CEO Next Level Occupational Therapy & CEO Home Therapy Solutions kara@nextlevelot.com
