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California Physical Therapy Assistants

Definition of a PTA

“Physical therapist assistant” means a person who is licensed pursuant to this chapter to assist in the provision of physical therapy under the supervision of a licensed physical therapist.

What activities are expressly prohibited?

A physical therapist assistant shall not:

    • Perform measurement, data collection or care prior to the evaluation of the patient by the physical therapist
    • Document patient evaluation and reevaluation
    • Write a discharge summary
    • Establish or change a plan of care
    • Write progress reports to another health care professional, as distinguished from daily chart notes
    • Be the sole physical therapy representative in any meeting with other health care professionals where the patient's plan of care is assessed or may be modified.
    • Supervise a physical therapy aide performing patient-related tasks
    • Provide treatment if the physical therapist assistant holds a management position in the physical therapy business where the care is being provided. For purposes of this section, “management position” shall mean a position that has control or influence over scheduling, hiring, or firing.

Can a PTA perform a functional capacity evaluation?

The Physical Therapy Board of California (Board) has concluded that only a physical therapist may perform a physical therapy functional capacity evaluation (FCE). This conclusion means that a physical therapist assistant may NOT perform a physical therapy FCE.

Practice Issue: Functional Capacity Evaluations Performed by Physical Therapist Assistants

What are the responsibilities of the PT when delegating to a PTA?

A licensed physical therapist shall at all times be responsible for the extent, kind, quality, and documentation of all physical therapy services provided by the physical therapist assistant.

The supervising physical therapist shall determine which elements of the treatment plan, if any, shall be assigned to the physical therapist assistant. Assignment of patient care shall be commensurate with the competence of the physical therapist assistant.

The physical therapist of record shall provide supervision and direction to the physical therapist assistant in the treatment of patients to whom the physical therapist assistant is providing care. The physical therapist assistant shall be able to identify, and communicate with, the physical therapist of record at all times during the treatment of a patient.

What type of therapist supervision is required?

“Adequate supervision”

A physical therapist shall at all times be responsible for all physical therapy services provided by the physical therapist assistant and shall ensure that the physical therapist assistant does not function autonomously. The physical therapist has a continuing responsibility to follow the progress of each patient and is responsible for determining which elements of a treatment plan may be assigned to a physical therapist assistant.

Can an assistant be supervised by a physical therapy student or graduate?

No. Physical therapist assistants shall not be independently supervised by a physical therapist license applicant or a physical therapist student.

Who is the therapist of record?

A physical therapist who performs the initial evaluation of a patient shall be the physical therapist of record for that patient. The physical therapist of record shall remain as such until a reassignment of that patient to another physical therapist of record has occurred. The physical therapist of record shall ensure that a written system of transfer to the succeeding physical therapist exists.

What is the ratio between supervising PTs and PTAs?

A physical therapist shall not supervise more than two (2) physical therapist assistants at any time to assist the physical therapist in his or her practice of physical therapy.

What must a PTA document?

The physical therapist assistant shall notify the physical therapist of record, document in the patient record any change in the patient's condition not within the planned progress or treatment goals, and any change in the patient's general condition.

Required designation for assistants

Only a person licensed as a physical therapist assistant by the board may use the title “physical therapist assistant” or “physical therapy assistant” or the letters “PTA” or any other words, letters, or figures that indicate that the person is a physical therapist assistant licensed pursuant to this chapter.

The license of a physical therapist assistant shall not authorize the use of the prefix “LPT,” “RPT,” “PT,” or “Dr.,” or the title “physical therapist,” “therapist,” “doctor,” or any affix indicating or implying that the physical therapist assistant is a physical therapist or doctor.

Can PTAs serve in leadership roles?

The position of the Physical Therapy Board of California regarding a physical therapist assistant serving in a leadership role was prompted by an inquiry that identified positions such as "team leaders" and "district managers" as individuals who are licensed as physical therapist assistants.

Specific questions presented for consideration by the Board were:

  • May a PTA serve as the exclusive physical therapy and rehab representative at a SNF (skilled nursing facility) weekly grand rounds/team conference situation where the patient's physical therapy treatment goals, program plan, treatment progress, and discharge plans are discussed with other treatment team members and decisions regarding program changes/additions may occur? (The physical therapist is not present.)
  • May a PTA conduct a screening of a SNF resident that may require a skilled physical therapy service and direct a physical therapist to seek a physicians order and evaluate the patient? (The screening would include a review of the medical record, verbal communications with the resident's professional nurse, and possibly a review of the functional performance of the resident.)
  • May a PTA write an appeal for Medicare payment? (The appeal would include an in depth review of the medical record (physicians notes, nurses notes, and physical therapy evaluations and notes), synthesis of record information and writing an appeal letter.)
  • May a PTA assign/reassign a SNF patient to a particular RUG (resource utilization group) that requires the patient to receive a specified numbers of minutes of therapy per week without input from or consultation with a professional physical therapist?

The answer to all of the above questions is no.

In each case the activity involves making decisions that encompass treatment planning or an evaluative judgment of the patient's condition. Question 2 specifically identifies a situation where the physical therapist assistant is giving direction to a physical therapist involving decisions that directly involve the physical therapy care that is to be provided. If a physical therapist assistant were to perform these activities, the physical therapist assistant would be performing in the capacity of a physical therapist.

In addition, the acceptance of any clinical leadership position necessitates a special condition for the physical therapist assistant. The physical therapist assistant in a leadership role for the clinical staff that includes a physical therapist may not personally perform any patient related service as a physical therapist assistant in the same practice.

The essential relationship between the supervising physical therapist and the supervised physical therapist assistant and mandates that the supervising physical therapist shall be responsible for the extent, kind, and quality of services provided by the physical therapist assistant. Section 1398.44 of the Board's regulations (Title 16 CCR) implements this statutory mandate by enumerating extensive supervisory duties of the physical therapist. Under these statutory and regulatory provisions it is the supervising physical therapist that must direct and supervise the physical therapy assistant. The physical therapist assistant who is supervised by the physical therapist cannot "clinically lead."

Finally, the Board must add that a physical therapist or a physical therapist assistant who fails to comply with the statutes or regulations administered by the Board is subject to revocation or suspension of the physical therapist's or the physical therapist assistant's authorization to practice.

Citation

16 CCR § 1398.44

Cal. Bus. & Prof. Code § 2601

Cal. Bus. & Prof. Code § 2622

Cal. Bus. & Prof. Code § 2630.3

Cal. Bus. & Prof. Code § 2633.5

Practice Issue: Physical Therapist Assistants Serving in Leadership Roles

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