If you treat in a setting that offers multiple types of therapy (e.g., physical therapy, occupational therapy, and/or speech-language pathology), then you likely have—or will—come upon a situation in which it is in a patient’s best interest to receive treatment in more than one discipline during a single session. And while this practice is absolutely permissible under Medicare policy, there are some special rules governing the manner in which you provide—and bill for—such services. These rules vary based on whether you are billing under Part A (which includes services provided in skilled nursing facilities) or Part B (which includes services provided in clinics, private practices, hospital outpatient facilities and, in some cases, skilled nursing facilities).

Part A

If, during a single treatment session, a patient receives therapy from two different practitioners working in two different disciplines (e.g., PT and OT), both therapists can bill for the entire treatment session separately. Furthermore, both would be responsible for following all rules regarding mode, modalities, and student supervision—as well as all other federal, state, practice, and facility regulations—throughout the duration of the session.

Part B

If two therapists provide treatment—whether that treatment includes the same or different services—to a single patient at the same time, neither therapist can bill separately for the full session. Basically, the total time billed between the therapists must be equal to the exact duration of the treatment session. So either:

  1. One of the therapists may bill for the entire session, while the other bills nothing; or
  2. The two therapists can split the billed units between them.

Please note that when one of the treating therapists is a speech-language pathologist, the guidelines are a bit different. According to the ASHA Leader, “Because SLPs usually bill treatment codes that represent a session (rather than an amount of time), and because Medicare has no published minimum/maximum session length, the SLP would bill for one untimed session.” The OT or PT would then bill “the timed treatment codes for the occupational or physical therapy.”

One important point to keep in mind, courtesy of joint guidelines for co-treatment created by the American Speech-Language-Hearing Association (ASHA), the American Occupational Therapy Association (AOTA), and the American Physical Therapy Association (APTA): Therapists billing under either Part A or Part B should only provide co-treatment if the purpose for such treatment is to enhance the quality of care the patient receives. Practitioners should never co-treat simply because it is logistically more convenient to do so. If the therapists believe co-treatment is the best way to help the patient progress toward his or her goals, they must clearly document that rationale within their notes. Finally, therapists should not provide therapy in more than two disciplines during a single session.


For more information regarding co-treatment—including three clinical examples—check out the joint guidelines referenced above. Still have questions? Leave ’em in the comment section below.

Down with Denials! 5 Claim Fixes to Make Sure Your PT Clinic Gets Paid - Regular BannerDown with Denials! 5 Claim Fixes to Make Sure Your PT Clinic Gets Paid - Small Banner
  • The Complete PT Billing FAQ Image

    articleMay 24, 2016 | 25 min. read

    The Complete PT Billing FAQ

    Over the years, WebPT has a hosted a slew of billing webinars and published dozens of billing-related blog posts. And in that time, we’ve received our fair share of tricky questions. Now, in an effort to satisfy your curiosity, we’ve compiled all of our most common brain-busters into one epic FAQ. Don’t see your question? Ask it in the comments below. (And be sure to check out this separate PT billing FAQ we recently put together.) Questions …

  • PQRS 2016: Everything PTs, OTs, and SLPs Need to Know Image

    webinarNov 4, 2015

    PQRS 2016: Everything PTs, OTs, and SLPs Need to Know

    At this point, you’d think satisfying PQRS requirements would be child’s play, but unfortunately, Medicare changes the rules every year. Fortunately, we’ve already combed through the 2016 Final Rule for you and organized everything you need to know about PQRS into a jam-packed, super educational 60-minute webinar. Join us for this beneficial seminar, where hosts Heidi Jannenga and Charlotte Bohnett will: detail 2016 reporting requirements; describe the different reporting methods; and explain how to ensure you successfully …

  • Denial Management FAQ Image

    articleMay 26, 2017 | 22 min. read

    Denial Management FAQ

    During our denial management webinar , we discussed the difference between rejections and denials, explained how to handle both, and provided a five-step plan for stopping them in their tracks. The webinar concluded with an exhaustive Q&A, and we’ve amassed the most common questions here. Insurance Issues Claim Quandaries Compliance Qualms Documentation Dilemmas Front-Office Frustrations Insurance Issues We’ve had issues with auto insurances denying 97112 (neuromuscular re-education) for non-neuro diagnoses, even in cases when the patient’s medical …

  • Common Questions from Our Medicare Open Forum Webinar Image

    articleOct 25, 2018 | 43 min. read

    Common Questions from Our Medicare Open Forum Webinar

    Earlier this week, WebPT President Dr. Heidi Jannenga, PT, DPT, ATC, teamed up with Rick Gawenda, PT—President and CEO of Gawenda Seminars & Consulting—to host a Medicare Open Forum . As expected, we received more questions than our Medicare experts could answer during the live session, so we've provided the answers to the most frequently asked ones below. Don't see the answer you're looking for? Post your question in the comment section at the end of this …

  • articleNov 7, 2013 | 2 min. read

    FLR and PQRS: How Are They Different?

    Functional limitation reporting (FLR) and PQRS both fall under the ever-widening umbrella of Medicare regulations, and they both involve outcome measures and data codes. Still, they are completely separate requirements, each with its own set of rules. Confusing, we know. To help you sort out the differences, we’ve put together a short breakdown of each one as well as a detailed compare/contrast chart: The Basics of FLR On July 1, 2013, Centers for Medicare & Medicaid Services …

  • Breaking News: 2017 MACRA Final Rule Hits Image

    articleOct 17, 2016 | 4 min. read

    Breaking News: 2017 MACRA Final Rule Hits

    After months of heated debate and public commentary—much of it coming from physicians who felt they needed more time to prepare themselves to participate in a brand-new quality reporting program—the Department of Health & Human Services (HHS) on Friday released its final rule on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) . This act, which will go into effect January 1, 2017, reimburses eligible Medicare physicians based on the quality of care they deliver …

  • Performance Rate vs. Reporting Rate: What It Means to Actually Satisfy PQRS Requirements Image

    articleNov 25, 2015 | 6 min. read

    Performance Rate vs. Reporting Rate: What It Means to Actually Satisfy PQRS Requirements

    Recently, we’ve received questions about what it really means to satisfy PQRS requirements. Specifically, there’s some confusion regarding what it takes to actually fulfill the requirements for satisfactory reporting of measures. So, let’s break it down. The purpose of PQRS is to measure quality, and that’s based on four factors: Measure eligibility Performance criteria or quality action Reporting rate Performance rate Measure Eligibility Every measure has specifications that eligible professionals (EPs) reference to determine whether they can …

  • 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 …

  • CMS’s Final Bow: The 2019 Final Rule Image

    articleNov 5, 2018 | 8 min. read

    CMS’s Final Bow: The 2019 Final Rule

    Last week, the Centers for Medicare and Medicaid Services (CMS) published its 2019 final rule . Clocking in at just over 2,300 pages, the final rule isn't exactly a light read—especially because the legal lingo can be harder to interpret than Shakespearean verse. Luckily, we have the script—with all its twists and turns—decoded and ready for you to review. Here's the synopsis of all the physical therapy, occupational therapy, and speech-language pathology Medicare changes for 2019: Out, …

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