Question: In a Medicare course I attended, the speakers stated that a PTA cannot supervise students in the SNF setting and bill Medicare. Is this correct?
Answer: Yes and no. Please read the following completely. The guidelines differ depending if you are billing Part A or Part B services.
Under Part A, the PTA cannot supervise students and bill Medicare for the students' time in treatment. The RAI Manual (Resident Assessment Instrument), the guide for completion the MDS and the regulations for what can be counted as therapy minutes under Part A, Chapter 3, page 3-185, states "Physical Therapy - Therapy services that are provided or directly supervised by a licensed physical therapist. A qualified physical therapy assistant may provide therapy but not supervise others (aides or volunteers) giving therapy. Include service provided by a qualified physical therapy assistant who is employed by (or under contract to) the nursing facility only if he or she is under the direction of a licensed physical therapist." Since the assistant must be supervised to bill Medicare, they in turn cannot supervise others.
When the assistant is providing services to a Part B beneficiary, Medicare states in the IOM (Internet Only Manual), Pub. 100-02, Coverage of services, Chapter 15, §230 Practice of Physical Therapy, Occupational Therapy and Speech-Language Pathology: B. Therapy Students "Only the services of the therapist can be billed and paid under Medicare Part B. The services performed by a student are not reimbursable even if provided under "line of sight" supervision of the therapist." In this case, "therapist" includes the PTA. The manual provides examples of when the services are billable under Part B and can be summarized as that the qualified therapist must be present in the room, must be guiding the student in service delivery and cannot be engaged in treating another patient or doing other tasks. What this means in regard to Part B is that a PTA can serve as a Clinical Instructor for a student, and while the student is treating the patient with the PTA, that time can be billed to Medicare. However, the PTA is doing nothing else but directing the student while the student is treating the patient.
It also states that the qualified practitioner is responsible for the services and as such, signs all documentation. It then continues "(A student may, of course, also sign but it is not necessary since the Part B payment is for the clinician's service, not for the student's services)."
The guidelines address the role of the assistant as a Clinical Instructor as follows: "Physical therapist assistants are not precluded from serving as clinical instructors for therapy students, while providing services within their scope of work and performed under the direction and supervision of a licensed physical therapist to a Medicare beneficiary."
The manual also addresses why there are differences between what is allowed under Part A and Part B. "The payment methodologies for Part A and B therapy services rendered by a student are different. Under the MPFS (Medicare Part B), Medicare pays for services provided by physicians and practitioners that are specifically authorized by statute. Students do not meet the definition of practitioners under Medicare Part B. Under SNF PPS, payments are based upon the case mix or Resource Utilization Group (RUG) category that describes the patient. In the rehabilitation groups, the number of therapy minutes delivered to the patient determines the RUG category. Payment levels for each category are based upon the costs of caring for patients in each group rather than providing specific payment for each therapy service as is done in Medicare Part B."
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.
Pauline M. Franko, PT 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. Danna Mullins is an associate and lecturer with Encompass and practicing physical therapist. You may contact the authors through the Encompass Website at www.encompassmedicare.com or by phone at 954-720-4087.