Recently, Heidi Jannenga, WebPT’s co-founder and president, co-hosted a webinar about Medicare misconceptions with compliance expert Tom Ambury. Following the webinar, we received quite a few questions regarding Medicare’s supervision requirements for therapy assistants, which we attempted to answer in this section of this FAQ document and this blog post. However, we thought we’d go one step further and provide you with clear-cut definitions of Medicare’s supervision levels—specifically: general supervision, direct supervision, and personal supervision. Here goes:

WebPT HEP - Regular BannerWebPT HEP - Small Banner

General Supervision

According to this Advance article and the APTA, under general supervision requirements, the licensed therapist must provide the initial direction of treatment and periodic assessments, but he or she does not need to be onsite during treatment—only reachable by phone.

Direct Supervision

According to the above-cited Advance article, Medicare’s direct supervision requirement dictates that the licensed therapist must be physically onsite (although not necessarily in the treatment room) and readily available to intervene if necessary. In other words, the therapist must be in the office and not otherwise engaged enough that he or she is unable to step in should the assistant—or patient—need help.

Personal Supervision

Per the above-cited APTA resource, the licensed physical therapist must be physically present in the treatment area and immediately available to intervene, direct, or alter the treatment or any other patient-related task for the duration of the service. The APTA also notes that some states allow physical therapy assistants to provide supervision in certain settings. However, Medicare will not cover such services. According to Advance, this level of supervision  (i.e., “line-of-sight” supervision) is only relevant for therapy aide supervision in a skilled nursing facility under Medicare Part A. Please note that “under Part B, aides cannot treat patients in any [setting] and bill their time to Medicare.”

Therapist Responsibility

Now, regardless of which payer you’re billing, what state you live in, or what setting you’re working in, the APTA makes one thing perfectly clear: the therapist “remains responsible for the physical therapy services provided when the physical therapist’s plan of care involves the physical therapist assistant.” To determine the appropriate level of assistant participation with a particular patient, therapists must consider the following:

  • “The [assistant’s] education, training, experience, and skill level
  • “Patient/client criticality, acuity, stability, and complexity
  • “The predictability of the consequences
  • “The setting in which the care is being delivered
  • “Federal and state statutes
  • “Liability and risk management concerns
  • “The mission of physical therapy services for the setting
  • “The needed frequency of reexamination”

Furthermore, no matter how involved a therapist assistant is in the treatment of a patient, the APTA says the therapist must still:

  1. Handle referrals.
  2. Perform the initial examination, evaluation, and re-examination (if necessary) as well as determine the diagnosis and prognosis.
  3. Develop—and revise when necessary—a plan of care that is based on the results of the initial examination or reexamination and includes treatment goals and outcomes;
  4. Determine whether a situation requires his or her “expertise and decision-making capability”—meaning that he or she should perform the treatment—or whether it would be appropriate for a therapy assistant to do so. (If the latter applies, the therapist should determine how best to use the therapy assistant in a manner that ensures a “delivery of service that is safe, effective, and efficient.”)
  5. Establish the patient’s discharge plan and complete thorough discharge documentation.
  6. Oversee “all documentation for services rendered.”

As a reminder, in outpatient private practice settings, Medicare requires direct supervision of therapy assistants. According to the same CMS document, this is also what’s known as in-the-office-suite supervision. In skilled nursing facilities, comprehensive outpatient rehabilitation facilities (CORP), rehab agencies, and home health agencies, Medicare requires general supervision. While some state practice acts and commercial insurance companies follow Medicare’s lead when it comes to establishing supervision requirements, some do not. Therefore, it’s important to know all the supervision requirements that apply to you, so you can adhere to the strictest one. When in doubt, review your state practice act and contact your local MAC or private insurance representative for clarification.

  • 2016 CPT Code Changes: What PTs, OTs, and SLPs Need to Know Image

    articleNov 11, 2015 | 2 min. read

    2016 CPT Code Changes: What PTs, OTs, and SLPs Need to Know

    January 1 marks the start of a brand new year. As we clean up the discarded party hats, noise-makers (i.e., pots and pans), and champagne flutes, we tend to reflect on the past year. Upon doing so, we often find that some of our old habits aren’t worth holding onto. That’s why many of us make new resolutions to adopt healthy lifestyle changes (new year, new you!), while simultaneously kicking our bad habits to the curb. But …

  • Founder Letter: My Evaluation of the New PT and OT Eval Codes Image

    articleNov 3, 2016 | 5 min. read

    Founder Letter: My Evaluation of the New PT and OT Eval Codes

    Over the last several years, healthcare providers in general—and rehab therapists, specifically—have been hit with a seemingly constant barrage of regulatory requirements. And the vast majority of these initiatives—PQRS, functional limitation reporting, MPPR, ICD-10, and the like—have either: Had a direct negative impact on our payments, or Forced us to devote extra time to satisfying the criteria of the requirements—with zero compensation for that time. So, it should come as no surprise that the rehab therapy community …

  • The Case of the Missing Modifier: 4 Clues as to Why Medicare is Denying Your Claims Image

    articleNov 10, 2016 | 6 min. read

    The Case of the Missing Modifier: 4 Clues as to Why Medicare is Denying Your Claims

    Missing modifiers are the worst—because when these pesky buggers don’t appear correctly on your claim forms, they can cause claim denials, which can back up your billing department and, ultimately, hurt your bottom line. While we usually can’t tell you exactly why Medicare slapped you with a denial notice on a particular claim, we can help you troubleshoot the cause. That way, you can ensure you’re submitting clean claims—with the correct modifiers—going forward. With that in mind, …

  • Evaluation Exam: Do You Know How to Use the New PT and OT Eval Codes? [Quiz] Image

    articleMar 3, 2017 | 1 min. read

    Evaluation Exam: Do You Know How to Use the New PT and OT Eval Codes? [Quiz]

    On January 1, 2017, new CPT codes went into effect for PT and OT evaluations and reevaluations. To use these new codes correctly, PTs and OTs must determine—and code for—the correct level of complexity associated with each patient evaluation. As with anything new, the implementation of these codes stirred up quite a few tough questions. Think you know how to use them? Test your skills on this quiz to be sure. After all, incorrect code selection could …

  • Founder Letter: 97002 and 97004 (Re-Evaluation) Myths Debunked Image

    articleJun 3, 2014 | 4 min. read

    Founder Letter: 97002 and 97004 (Re-Evaluation) Myths Debunked

    Let’s start off with a hypothetical example: You’re working with a Medicare patient. It’s the tenth visit and you need to conduct a routine reassessment, so you complete a progress note. Your boss then asks why you didn’t bill for a re-evaluation. Should you have? This scenario happens daily. If it’s not your boss questioning you, then maybe it’s yourself asking, “Should I bill a re-evaluation code for the time spent completing my reassessment of this patient?” …

  • The Definitive Medicare Part B FAQ for Outpatient PT, OT, and SLP Image

    articleOct 27, 2016 | 33 min. read

    The Definitive Medicare Part B FAQ for Outpatient PT, OT, and SLP

    In October, we hosted a webinar dedicated to the most common Medicare misconceptions . We received a lot of questions from the audience—so many, in fact, that we’ve organized them all into one huge FAQ. Scroll through and check them out, or use the link bank below to skip to a particular section. The Therapy Cap ABNs Modifiers Supervision Prescriptions and Certifications Cash-Pay Rules and Regulations Re-Evaluations Everything Else   The Therapy Cap If a patient reaches …

  • PT and OT Evaluation Codes Cheat Sheet Image

    downloadDec 21, 2016

    PT and OT Evaluation Codes Cheat Sheet

    As of January 1, 2017, PTs and OTs must use a new set of CPT codes to bill for patient evaluations and re-evaluations. But, it's not a simple swap-out across the board; instead, when coding for initial evaluations, therapists must now select one of three codes, which are tiered according to the complexity of the evaluation. But, what separates a low-complexity evaluation from a moderate- or high-complexity one? And how should therapists go about making their coding …

  • Farewell, 97001: How to Use the New PT and OT Evaluation Codes Image

    articleOct 12, 2016 | 8 min. read

    Farewell, 97001: How to Use the New PT and OT Evaluation Codes

    Hear ye, hear ye: We hereby declare that as of January 1, 2017, all PTs and OTs must begin using a new set of CPT codes to bill for therapy evaluations and re-evaluations. Actually, if we are being perfectly accurate, we’re not declaring anything; CMS and the AMA are—and we’re merely the messengers. You might find it hard to believe, but with this CPT coding update, the evaluation and re-evaluation codes that PTs and OTs have come …

  • The Ultimate ICD-10 FAQ: Part Deux Image

    articleSep 24, 2015 | 16 min. read

    The Ultimate ICD-10 FAQ: Part Deux

    Just when we thought we’d gotten every ICD-10 question under the sun, we got, well, more questions. Like, a lot more. But, we take that as a good sign, because like a scrappy reporter trying to get to the bottom of a big story, our audience of blog readers and webinar attendees aren’t afraid to ask the tough questions—which means they’re serious about preparing themselves for the changes ahead. And we’re equally serious about providing them with …

Achieve greatness in practice with the ultimate EMR for PTs, OTs, and SLPs.