Medicaid Rules for PTA Supervision

Question: My boss has been putting a bit of pressure on me for an answer to this question. Do I treat Medicaid patients as I would with a Medicare patient with regard to PTA supervision, recording of billable time, certifications and recertifications? I always have, but am being asked to allow my Medicaid patients to be seen by my PTAs on days that I am not at that clinic. I have searched several places for an answer, but there is nothing listed online for Medicaid.

Answer: As Medicaid is a state administered insurance plan, there are 50 sets of regulations governing Medicaid, and you would have to look into the guidelines for your state. However, we are not aware of any specific guideline relating to PTA supervision under any state Medicaid rules, but our knowledge is not exhaustive about this.

Medicare regulations cover Medicare patients, just the same way as private insurance companies and the Medicare Advantage program have their own regulations covering care for their beneficiaries. Each company has guidelines for their care, although some closely mimic Medicare regulations.

If there are no guidelines from your state Medicaid regulations, you and your boss should look at your state practice act for guidance and follow what it allows.

Question: I was reading through some "Medicare Advisor" archives and came across an article on Feb. 13, 2007. I wanted to see if I could get more clarification on billing the non-Medicare insurance patient.

If at anytime I am providing one-on-one care with a Medicare patient and an "independent activity" with a non-Medicare patient, would I just not charge for the "independent activity" time for the non-Medicare patient? Does this apply to the Medicare patient if the situation was reversed?

I know you can bill this treatment as "supervised" for Medicare, but wouldn't you just not charge for the time the patient was performing "independent activities" and put it under non-treatment time since it was not skilled therapy? The article states that Medicare acknowledges this method of treatment as "supervised" therapy and it can be suitable but must be billed as group. But then how would you bill the non-Medicare patient when a group charge is not applicable?

Answer: Always remember that each individual insurance plan has its own regulations and you should be aware of their policies. Therefore, for Medicare, if you are providing direct one-on-one services to a Medicare beneficiary while another patient is carrying out "independent activities" (i.e., non-skilled treatment, whether covered by Medicare or not), you would bill Medicare for the time spent on skilled treatment and the other patient would not be billed for that time as it is a non-skilled service. If you are providing one-on-one care to the Medicare patient and, at the same time the other patient is performing an activity that you are observing and providing feedback, then Medicare refers to this as "supervised therapy" because you are not exclusively working with their patient. In this instance, the Medicare patient would be billed the group code, while the other patient would be billed according to their insurance plan guidelines.

Disclaimer: The answers that we provide are based on Medicare guidelines for what is payable under the Medicare Part A and Part B Benefit. As always, the provider should be aware of the other regulations that might supersede the Medicare payment guidelines such as the State Practice Act and the State Administrative Code. In any scenario, the practitioner must go with the most stringent requirement in order to be compliant. The information provided is current as of the time of publication.

If you have a question about Medicare reimbursement you would like the authors to address, send your question and contact information to Medicare Advisor, c/o Lisa Lombardo, ADVANCE for PTs & PTAs, 3100 Horizon Dr., King of Prussia, PA 19406; fax 610-275-8562;

Pauline M. Franko is owner of Encompass Consulting & Education, LLC, a consulting and education company specializing in Medicare consulting, compliance and training based in Tamarac, FL. The company's "Direction on Demand" service specializes in providing the rehabilitation professional with a clear, easy way to understand how to provide Medicare compliant services to their patients in the SNF and outpatient settings. As an associate in Comprehensive Medicare Consultants, LLC, she is responsible for assisting with and directing compliance programs to rehab agencies. Danna Mullins is an associate and lecturer with Encompass. Contact the authors through the Encompass website at or by phone at 954-720-4087.


What are the Oregon guidelines on needing a physical location in state to service medicaid patients.

Kare September 28, 2009


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