Question: I'm a prn PT in Pennsylvania. Recently I was employed at a nursing facility where the PTA was performing screens, writing discharge summaries (that were to be co-signed by a PT) and recertification orders (also co-signed by a PT). I was very uncomfortable with him continuing to do this while he was under my supervision, even though his company informed him that this was an acceptable practice. If this is not allowed by the Physical Therapy Practice Act, I would like to provide him with a copy of that part of the Act that refers to these issues. I did find Section 40.53 that precludes a PT from delegating the performance of discharge summaries to a PTA, but no information regarding screens or recertification summaries/orders. Thanks for your help.
Answer: You have obviously found the Pennsylvania PT Practice Act. Each state has their own practice act. Most state practice acts include verbiage that precludes therapists from delegating duties to PTAs that are outside of their scope of practice.
Medicare is very explicit in its regulations covering Part B patients and what PTAs are allowed to document. Under Part B, an assistant cannot write discharge summaries, the progress report required every 10th treatment or 30 days whichever is the least, and the updated plan of treatment (recertification). As to Part A, Medicare has no documentation guidelines as yet as they pertain to a PTA, although CMS is considering using the same guidelines for documentation in all sites of service. We do not believe that, in the skilled nursing setting, documentation should be any different from Part B.
As for screens and the screening process, the American Physical Therapy Association's stance is that they contain clinical assessment which is out of the scope of practice of a PTA. As the Medicare advisors, we recommend that if a screening is actually needed (and we have a definite opinion on that topic) and it is done by an assistant, any request for therapy services should be made by the therapist.
Question: I am looking for the Medicare Physician Fee Schedule for physical therapy codes. I have looked all over the Medicare Website and I cannot locate it. I was hoping you could help me.
Answer: You should be able to obtain that information from your Medicare contractor or your facility billing office. You can go on the Web to www.cms.hhs.gov/apps/pfslookup/step1.asp and look up specific codes based on contractor or location. You would go through the Physician Fee Schedule link.
Question from the Blog: I am a PTA in a SNF. I work under the supervision of a RPT. My question is about the number of PTAs the PT can supervise. My practice act states 4, but does that mean 4 on the clock at the same time, or does that include the PRN (replacement) PTAs when I can't cover my treatments. This happens for vacations, very large caseloads and sick days.
Answer: This is a state specific question, so you will have to either obtain a copy of your State Practice Act or contact your State Board by phone or e-mail for clarification on this question.
Pauline M. Franko, PT is owner of Encompass Consulting & Education, LLC; a consulting and education company specializing in Medicare 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. You may contact the authors through the Encompass website at http://www.encompassmedicare.com/ or by phone at 954-720-4087.