Medicare Compliance & Reimbursement

You aren't alone if you've been worried about the 2008 Medicare Physician Fee Schedule's restrictive statements on therapist qualifications.

From foreign-trained therapists to therapy assistants who became full-fledged therapists without going back to school, therapy providers across the nation who received their credentials via non-traditional routes have feared for their jobs. And home care providers short of therapists have worried about their staffing.

The good news: In Transmittal No. 88 (CR 5921), the Centers for Medicare & Medicaid Services spells out more detailed requirements for PTs, PTAs, OTs and OTAs -- and experts agree that the requirements are actually quite inclusive.

Jan. 1, 2010 may seem like a long way off, but after that date, anyone who becomes a PT, PTA, OT or OTA must follow new standards for Medicare. You can find all guidelines starting on page 38 of Transmittal 88 at http://www.cms.hhs.gov/Transmittalsdownloads/R88BP.pdf.

Take a look at the new requirements:

• PTs must be licensed in their state (if licensure applies). This may include temporary licensure, CMS clarified. In addition, PTs must have graduated from a PT education program accredited by the Commission on Accreditation in Physical Therapy Education (CAPTE) and have passed a national exam that's approved by the state where the PT will be practicing.

• PTAs must be licensed (if applicable) and be registered or certified (if applicable) by their state. Licensure may include temporary licensure. In addition, they must have graduated from a CAPTE-accredited program and have passed a national exam for PTAs.

• OTs must be licensed as an OT (if applicable) in their state and have graduated from a program accredited by the Accreditation Council for Occupational Therapy Education (ACOTE). Licensure may be temporary. In addition, they must be eligible to take or have passed the OT exam administered by the National Board for Certification in Occupational Therapy (NBCOT).

• OTAs must be licensed (if applicable) or otherwise regulated (if applicable) as an OTA in their state. They must have graduated from an OTA program that's ACOTE-accredited and either be eligible to take or have successfully completed the NBCOT exam for OTAs.

Three simple rules: If these regs seem overwhelming, remember the basics: the new standards require therapists to 1) be licensed if their state offers licenses, 2) have graduated from an accredited program, and 3) have taken their national exam.

Grandfathering options: If you know you have current therapists and assistants who fall short of the new standards, rest assured that they're probably in the clear. First of all, the new standards go into effect for new grads after Jan. 1, 2010, so anyone who's currently practicing is likely covered by one of many grandfathering clauses CMS included in Transmittal No. 88.

Example: In the late 1970s, OTAs with experience could participate in a Career Mobility Program that would allow them to become OTs if they passed the national OT exam.

As another example, CMS was "a little more permissive to make sure those who are currently practicing as internationally-educated therapists don't get cut out," says Dave Mason of the American Physical Therapy Association.

But if you plan on hiring internationally-educated PTs on or after Jan. 1, 2010, take note. Their curricula must be approved by a credentials evaluation organization either approved by APTA or "identified in 8 CFR 212.15(e) as it relates to PTs," according to CMS. As of 2007, approved organizations in CFR 212.15 (e) included the Federation of State Boards of Physical Therapy and the Foreign Credentialing Commission on Physical Therapy.

For internationally-educated or military-trained PTAs, their curricula must be approved by a credentialing body that either the APTA or 8 CFR 212/15 (e) endorses.

Note: Transmittal 88 did not include any new education standards or professional qualifications for SLPs.