Medicare Compliance & Reimbursement

Here's what it means for the rehab industry

While tightening incident-to billing requirements in physicians' offices, the Centers for Medicare & Medicaid Services throws therapists another bone by loosening supervision requirements in therapy practices.

CMS proposes to loosen supervision requirements for PTAs and COTAs in private practice settings under the 2005 physician fee schedule. Under current regulations, Medicare covers these services only if the PT or OT provides "personal supervision," which means she must be in the room while the assistant provides services.

The proposed change from personal to direct supervision for private therapy practices is in line with what most state practice acts require for hospital outpatient departments, says Rick Gawenda, director of rehab services for Detroit Receiving Hospital. The less restrictive requirement is more practical, he adds.

Under the proposed rule, services provided by PTAs and COTAs will require only "direct supervision" for Medicare coverage, which means the PT or OT must be "in the office suite."

To "directly" supervise an assistant, the PT wouldn't necessarily have to be onsite - he or she could be offsite and available by telephone, clarifies Michael Weinper, CEO of Physical Therapy Providers Network (PTPN) of Calabasas, CA. "But this does not mean that assistants should treat Medicare patients without the [PT's] involvement. The therapist still needs to be actively involved in the care."

Example: If a PT employs a PTA, and the PT provides those procedures that only she is qualified to perform, then takes her lunch break and goes out with her cell phone while the PTA finishes the treatment, that would be direct supervision, Weinper explains.