Supervisory Visit Requirements in Home Health (2026): Complete Guide to 42 CFR 484.80 and Therapy Reassessment Rules

Home health supervisory visits are required at two intervals: every 14 days for home health aide services under 42 CFR 484.80, and every 30 days for therapy assistant reassessments under 42 CFR 409.44. Missing either window is a Condition of Participation violation that puts your Medicare certification at risk.

This guide covers every discipline-specific requirement, the regulatory language behind each rule, and what surveyors actually check.

Federal Supervision Requirements (42 CFR 484.80)

Two federal regulations establish the core supervision requirements. 42 CFR 484.80 governs home health aide services, including the 14-day supervisory assessment rule. 42 CFR 409.44 governs skilled services, including the 30-day functional reassessment when therapy assistants are delivering care. State practice acts may impose additional requirements — always comply with whichever standard is more stringent.

Here is how supervision requirements break down across every discipline pair:

PT Supervision of PTAs

When a Physical Therapist Assistant delivers home health services, the supervising Physical Therapist has three non-delegable responsibilities defined in 42 CFR 409.44:

Initial evaluation. Only a qualified PT can perform the initial patient evaluation, establish the plan of care, and determine eligibility for the Medicare home health benefit. A PTA cannot perform evaluations under any circumstances.

30-day functional reassessment. At least every 30 calendar days, the supervising PT must personally provide the therapy service and functionally reassess the patient. This must include objective measurements — range of motion, gait speed, functional mobility scores — that allow comparison across successive visits.

Discharge assessment. Only the qualified PT can perform the discharge assessment and determine when skilled services are no longer needed.

The 30-day clock starts from the date of the last qualified therapist visit. If the PT completes a reassessment on day 25, the clock resets from that date. If the 30-day period expires without a reassessment, PTA visits after that date are non-billable.

Real-World Scenario

A PT evaluates a patient on March 1 and delegates routine visits to a PTA. By March 31, the PT must have treated the patient and completed a functional reassessment. If the PT's visit slips to April 3, the PTA's visits on April 1 and 2 cannot be billed.

CMS permits exceptions for hospitalizations or unexpected condition changes. The 30-day clock pauses until the physician orders therapy to resume, but the exception must be documented.

OT Supervision of COTAs

COTA supervision requirements mirror the PTA structure under the same regulation (42 CFR 409.44). The supervising OT holds identical non-delegable responsibilities: initial evaluation, 30-day functional reassessment with objective measurements, and discharge assessment.

As an OTR/L, I want to emphasize a point that trips up agencies: if a patient receives both PT and OT and both disciplines use assistants, each discipline requires its own 30-day reassessment by the respective qualified therapist. A PT reassessment does not satisfy the OT requirement.

One additional rule applies to COTAs specifically: under 42 CFR 409.44(c)(2)(iii)(C), only a qualified therapist can deliver maintenance therapy. If a patient transitions from restorative to maintenance OT, the supervising OT must take over direct care.

Clinical notes written by PTAs and COTAs must include the date, signature and credentials, objective measurements relative to each treatment goal, and reference to the current plan of care.

RN Supervision of LPNs/LVNs

Unlike HHA and therapy assistant rules, federal regulations do not prescribe a specific supervisory visit frequency for LPN/LVN supervision in home health. Under 42 CFR 484.75, skilled professional services must be "authorized, delivered, and supervised only by health care professionals who meet the appropriate qualifications specified under 484.115."

In practice, this means:

The RN authorizes and oversees LPN/LVN care. The RN develops the plan of care, and the LPN/LVN performs skilled nursing tasks within their scope under RN direction.

State practice acts govern the specifics. Most states require "general supervision" — the RN must be available by telecommunications while the LPN is providing care. Some states require periodic in-person visits (commonly every 30 or 60 days) and co-signatures on LPN documentation.

The initial assessment must be performed by an RN. Under 42 CFR 484.55, the comprehensive patient assessment must be completed by a registered nurse. An LPN cannot perform the initial home health assessment.

Best practice: Establish an internal supervision schedule for LPN/LVN care and document it in policy. Surveyors will ask, and "we follow the state practice act" without implementation documentation is a finding waiting to happen.

Home Health Aide Supervision

HHA supervision under 42 CFR 484.80(h) is the most prescriptive supervision requirement and the most frequently cited deficiency on home health surveys.

Patients receiving skilled services (14-day rule). An RN or appropriate skilled professional must complete a supervisory assessment no less frequently than every 14 days. The aide does not need to be present. One virtual assessment (two-way audio-video) is allowed per 60-day episode — all others must be onsite. An annual in-person joint visit to observe the aide performing care is still required regardless of the 14-day cadence.

Patients receiving only aide services (60-day rule). An RN must visit onsite every 60 days to assess care quality. Semi-annually, the RN must observe the aide performing care (mandatory joint visit).

When deficiencies are identified. The aide must be retrained, then pass an onsite competency evaluation with the supervisor present before resuming independent care.

Documentation Requirements

Surveyors verify that documentation substantiates what happened during each supervisory visit. Each type requires specific elements:

HHA supervisory assessments: Date, time, onsite vs. virtual designation, assessment of aide's adherence to the care plan, patient satisfaction, changes needed to aide duties, competency concerns and corrective actions, supervisor's signature and credentials.

Therapy assistant reassessments: Date, objective functional measurements, comparison to prior data points, determination of continued skilled need, plan of care modifications, supervising therapist's signature and credentials.

LPN/LVN supervision: Documentation per agency policy and state requirements, RN co-signature where required, plan of care changes based on RN assessment.

Common Compliance Mistakes

Treating the 14-day rule as a 14-visit rule. The requirement is 14 calendar days, not 14 visits. If an aide sees a patient three times per week, two supervisory assessments per month are still required.

Letting the 30-day therapy clock lapse during scheduling gaps. If the PT is on vacation and no other qualified PT is available, the PTA's visits become non-billable after day 30. Build a coverage plan for therapist absences.

Using phone calls as supervisory visits. Except for one virtual audio-video visit per 60-day episode (HHA only), phone check-ins do not count. Visits must be onsite and in person.

Failing to document objective measurements. "Patient is progressing well, continue POC" does not meet the standard. CMS requires objective measurements that enable comparison across assessments.

Assuming one supervisor covers all disciplines. An RN supervisory visit does not satisfy a PT's 30-day PTA reassessment obligation. Each discipline pair has its own clock.

Not tracking contracted aides. Agencies remain fully responsible for supervision even when using staffing agency aides.

Frequently Asked Questions

How frequently do you do a supervisory visit for a physical therapist assistant? Every 30 calendar days. Under 42 CFR 409.44, a qualified PT must provide the therapy service and functionally reassess the patient at least once every 30 days when a PTA is delivering care.

Can a supervisory visit be done virtually? For HHA supervision only, one virtual assessment per 60-day episode is permitted via two-way audio-video. Therapy assistant reassessments must be in-person because the supervising therapist must personally provide the therapy service.

Does the home health aide need to be present during the supervisory visit? Not for the routine 14-day assessment. The aide must be present for the annual competency observation and any remediation visits following identified deficiencies.

What happens if a 30-day therapy reassessment is missed? PTA or COTA visits after the 30-day window expires are non-billable. Claims can be denied on audit, and state licensing boards may take action.

Do COTA supervisory visit requirements differ from PTA requirements? Federal requirements are identical: 30-day reassessment by the qualified therapist with the same non-delegable responsibilities. State practice acts may impose additional requirements for one discipline but not the other.

Who can supervise an LPN in home health? A registered nurse. The specific supervision model (general, direct, or periodic) is determined by state practice act. At the federal level, 42 CFR 484.75 requires RN oversight for LPN services.

Is the 14-day HHA supervision rule a Condition of Participation? Yes. It falls under 42 CFR 484.80. Violations result in survey deficiencies, and repeated non-compliance can escalate to immediate jeopardy findings threatening Medicare certification.