Home Care Therapy Eval does not take place until the 15th visit?

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I have had a number of customers mention that while they may try their best, due to the use of subcontractors etc, it is often very difficult to establish when the 13th and 19th Home Care therapy visit actually takes place.  As a result, it is possible that the actual re-evaluation does not occur until after the 13th (the 15th for example).  Medicare Guidelines state that you should mark the 13th and 14th visit as non-billable and they "recommend" you display them as non-covered charges on the claim.  This would make the 15th visit the 13th billable visit.  what are your thoughts on this? 

thanks to the folks at the Florida Association for Homecare who provided the following interpretation.

Attention Members,

Please review the communication below carefully. This update was sent from the National Organization which was based upon clarification they received directly from CMS. I have highlighted areas that you should pay particular attention to. CMS has previously stated that you only count billable visits in your overall therapy visit count when determining when the 13^th or 19^th reassessment should occur.  So as an example, if you did not complete the reassessment on visit #13 & the assessment was not completed until let’s say visit #16, according to the information below, visits 14,15, and 16 would then be non-billable. In addition under this principal visit #17 would resume your “billable” visit count but technically only count as the 14th visit in the total overall billable visits (working toward the next reassessment threshold of 19 visits). The link contained in the first paragraph below, takes you to the CMS Therapy Q&A page, which was last updated 5/5/11. It is also worth noting and passing this along to your billing department CMS’s clarification on how “non-billable” visits should be reported.

This requirement continues to become more and more confusing. Please do not hesitate to submit any questions you have and we will strive to obtain the answers we all need.