Show Often times therapists end up working in a private practice after working in a hospital or a rehab agency and may inadvertently think that the same supervision rules apply. Therapy Supervision – Know the RulesThe Medicare basis for therapy supervision rules for outpatient rehabilitation therapy services are the same as those for diagnostic tests defined in 42CFR410.32. (Code of Federal Regulations) Depending on the setting, the supervision levels include personal supervision (in the room), direct supervision (in the office suite), and general supervision (is available but not necessarily on the premises). Per CMS ” Services that can be safely and effectively furnished by nonskilled personnel or by PTAs or OTAs without the supervision of therapists are not rehabilitative therapy services.” In the Medicare Benefits Policy Manual, Chapter 15, CMS describes the services of a physical therapist assistant (PTA):
This lays necessary policy guidance to describe supervision:
For example, in clinics, rehab agencies, and public health agencies, 42CFR485.713 indicates:
While the above examples addresses physical therapist assistants CMS also provides similar guidance for occupational therapy assistants (OTAs) in the Medicare Benefits Policy Manual, Chapter 15 at Section 230.2 (C). CMS does not allow for the services of a speech-language pathology assistant to be billed to Medicare. In a nutshell, PTAs and COTAs in private practice must have direct (onsite) supervision by the supervising PT or OT in order to bill Medicare. PTAs and COTAs working in hospitals, rehab agencies and CORFs require general supervision, and the supervising therapist must be available, but does not need to be on the premises. Review this blog post for guidance on TRICARE and the use of PTAs in private practice. If you are a Medicaid provider ensure that you know the supervision rules. And in all instances reference an updated copy of the PT and OT practice acts in your state to ensure compliance with supervision rules. Stay tuned for a future post on supervision and use of assistants will billing incident-to. Do you have PTAs and COTAs providing services in your outpatient therapy rehab program? Are these services billed to federal healthcare programs including Medicare, Medicaid and Tricare? Is your supervision policy compliant with both payor polices and your practice act?
Nancy J. Beckley MS, MBA, CHC: President-Nancy Beckley & Associates LLC. Compliance outsourcing, risk assessment, compliance plans, compliance
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Reader InteractionsWhat is the definition for supervision of a PTA in the state of Florida?Except in a case of emergency, direct supervision requires the physical presence of the licensed physical therapist for consultation and direction of the actions of a physical therapist or physical therapist assistant who is practicing under a temporary permit and who is a candidate for licensure by examination.
How many aides can a PTA supervise in California?Aide—A licensed physical therapist may utilize the services of one aide to provide assistance in patient-related tasks.
How many PTA can a PT supervise in Maryland?A physical therapist may not be responsible for the direction and supervision of more than three full-time physical therapist assistants, or three FTE's (full-time equivalency totaling 120 work hours per week) requiring supervision, including temporary physical therapists, temporary physical therapist assistants, and ...
How many PTAs can a PT supervise in Michigan?A PT may not supervise more than 4 PTAs at one time
A physical therapist who delegates acts, tasks, functions, or interventions shall also comply with all of the following: (a) Ensure the qualifications of the PTA under the PT's supervision, including verification of the PTA's training, education, and licensure.
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