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Medicare Services and Therapy Students

Posted January 25, 2023

The rules for therapy students are different in outpatient and inpatient settings.

Medicare Outpatient Settings – Part B

Only the services of the therapist can be billed and paid under Medicare Part B. The services performed by a student are not reimbursed even if provided under “line of sight” supervision of the therapist; however, the presence of the student “in the room” does not make the service unbillable.  Group therapy services performed by a therapist or physician may also be billed when a student is also present “in the room”.

Medicare will pay only for the direct (one-to-one) patient contact services of the physician or therapist provided to Medicare Part B patients.   

Therapists may bill and be paid for the provision of services in the following scenarios:

    • The qualified practitioner is present and in the room for the entire session.
    • The student participates in the delivery of services when the qualified practitioner is directing the service, making skilled judgment, and is responsible for the assessment and treatment.
    • The qualified practitioner is present in the room guiding the student in service delivery when the therapy student and the therapy assistant student are participating in the provision of services, and the practitioner is not engaged in treating another patient or doing other tasks at the same time.
    • The qualified practitioner is responsible for the services and as such, signs all documentation. (A student may contribute to the documentation but it must be reviewed and signed by the supervising therapist or assistant).

When a therapy student is involved the skilled minutes of the qualified clinician may be counted and coded when all requirements listed above are met.

Therapy Assistants as Clinical Instructors

PTAs and OTAs 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 or occupational therapist to a Medicare beneficiary.


Medicare Inpatient Settings – Part A

Therapy Students


Therapy students are not required to be in line-of-sight of the supervising therapist/assistant. The determination of whether or not a student is ready to treat patients without line-of-sight supervision is left to the discretion of the supervising therapist/assistant.

Time may be coded on the Minimum Data Sets (MDS) when the therapist provides skilled services and direction to a student who is participating in the provision of therapy. All state and professional practice guidelines for student supervision must be followed.

Individual Therapy

Individual therapy is for treatment of one (1) patient at a time. When a therapy student is involved the minutes may be coded when only one (1) patient is being treated by the therapy student and the supervising therapist/assistant.

The supervising therapist/assistant cannot be treating or supervising another individual and he/she must be available to immediately assist the student as needed.

Concurrent Therapy

Concurrent therapy is for treatment of two (2) residents who are performing different activities at the same time and are both in line-of sight of the treating therapist/assistant.

When a therapy student is involved the minutes may be coded when one of the following occurs:

    • Student is treating one (1) patient and the supervising therapist/assistant is treating another patient and both patients are in line of sight of the therapist/assistant or student; or
    • Student is treating two (2) patients both of whom are in line-of-sight of the student and the therapist/assistant is not treating any patients and is not supervising other individuals; or
    • Student is not treating any patients and the supervising therapist/assistant is treating two patients at the same time both of whom are in line-of-sight.

Group Therapy

Group therapy is for treatment of four (4) patients who are performing the same or similar activities and are supervised by a therapist/assistant who is not supervising any other individuals.

When a therapy student is involved with group therapy the minutes may be coded when one of the following occurs:

    • Student is providing group treatment and the supervising therapist/assistant is not treating any patient and is not supervising other individuals (students or patients); or
    • Supervising therapist/assistant is providing group treatment and the student is not treating any patient.

Reference

Medicare LCA: Billing and Coding: Therapy Students and Aides A53339

Medicare Benefit Policy Manual Ch. 15 § 230

About Us

Zachary Edgar JD, LLM is the managing partner for Therapy Comply.  Zachary is a healthcare attorney that specializes in federal and state healthcare regulatory issues particularly for physical, occupational, and speech therapy practices.  

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