Who can provide therapy services other than physical, occupational, or speech therapists?

Therapy services can be provided to Medicare patients by physicians and non-physician practitioners (NPPs) such as nurse practitioners and physician assistants if all of the other coverage requirements for therapy services have been met.

What does therapy services provided “incident to” the services of a physician/NPP mean?

Therapists who are not enrolled in Medicare may provide therapy services to Medicare patients under the physician/NPP’s NPI.

Does the physician/NPP need to supervise the therapist?

Yes.  Therapists billing incident to a physician/NPP must be directly supervised by the physician/NPP, this means the physician/NPP must be on-site but not necessarily in the same room.

Can a therapist bill incident to another therapist?

No.  There is no coverage for services provided incident to the services of a therapist.  A therapist who is not enrolled in Medicare cannot bill under the NPI of a therapist who is enrolled.

Can assistants bill incident to a physician/NPP?

 No.  Assistants can only bill under the supervision of an enrolled physical or occupational therapist.  However, if a PT and PTA (or an OT and OTA) are both employed in a physician’s office, the services of the PTA, when directly supervised by the PT or the services of the OTA, when directly supervised by the OT may be billed by the physician group as PT or OT services using the PIN/NPI of the enrolled PT (or OT).

If the PT or OT is not enrolled, Medicare will not pay for the services of a PTA or OTA billed incident to the physician’s service.

Can other healthcare practitioners bill therapy services incident to a physician/NPP?

Regardless of any state licensing that allows other health professionals to provide therapy services, Medicare is authorized to pay only for services provided by those trained specifically in physical therapy, occupational therapy or speech-language pathology.

The services of athletic trainers, massage therapists, recreation therapists, kinesiotherapists, low vision specialists or any other profession may not be billed as therapy services.

Reference

Medicare Benefit Policy Manual

Chapter 15 – Covered Medical and Other Health Services

230.5 - Physical Therapy, Occupational Therapy and Speech-Language Pathology Services Provided Incident to the Services of Physicians and Non-Physician Practitioners (NPP)