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  • Medicare Supervision of Occupational Therapy Assistants

Supervision of Occupational Therapy Assistants 

Definitions

Supervision Levels for outpatient rehabilitation therapy services are the same as those for diagnostic tests defined in 42 CFR 410.32. Depending on the setting, the levels include personal supervision (in the room), direct supervision (in the office suite), and general supervision (physician/NPP is available but not necessarily on the premises):

General supervision means the procedure is furnished under the physician's (OT’s) overall direction and control, but the physician's (OT’s) presence is not required during the performance of the procedure. Under general supervision, the training of the nonphysician (OTA) personnel who actually perform the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician (OT). 

Direct supervision in the office setting means the physician (OT) must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician OT) must be present in the room when the procedure is performed. (On-Site Supervision)

Personal supervision means a physician (OT) must be in attendance in the room during the performance of the procedure.

Private Practice

Direct supervision by a occupational therapist (for OTAs) is required when assistants provide therapy services in the private practice setting or in the office of a physician/NPP.

In order to qualify to bill Medicare directly as a therapist, each individual must be enrolled as a private practitioner and employed in one of the following practice types:

    • An unincorporated solo practice,
    • Unincorporated partnership,
    • Unincorporated group practice,
    • Physician/NPP group or groups that are not professional corporations, if allowed by state and local law.

Physician/NPP group practices may employ TPP if state and local law permits this employee relationship.

Private practice also includes therapists who are practicing therapy as employees of another supplier, of a professional corporation or other incorporated therapy practice. Private practice does not include individuals when they are working as employees of an institutional provider.

Physician’s Office

Direct supervision by a occupational therapist (for OTAs) is required when assistants provide therapy services in the private practice setting or in the office of a physician/NPP.

Therapy Provided “Incident-to” Physicians and Physician Employees

Physical and occupational therapy services may be provided by physicians, non-physician practitioners (NPPs), or incident-to the services of physicians/NPPs when provided by physical or occupational therapists, in the office or home.  Therapy services must be directly supervised

The services of PTAs and OTAs also may not be billed incident to a physician’s/NPP’s service. 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 shall not pay for the services of a PTA or OTA billed incident to the physician’s service, because they do not meet the qualification standards in 42 CFR 484.4. 

Home Health

The service of a physical therapist, or occupational therapist is a skilled therapy service if the inherent complexity of the service is such that it can be performed safely and/or effectively only by or under the general supervision of a skilled therapist.

Initial Assessment: For each therapy discipline for which services are provided, a qualified therapist (instead of an assistant) must assess the patient’s function using a method which objectively measures activities of daily living such as, but not limited to, eating, swallowing, bathing, dressing, toileting, walking, climbing stairs, using assistive devices, and mental and cognitive factors. The measurement results must be documented in the clinical record.

Reassessment at least every 30 days (performed in conjunction with an ordered therapy service):  At least once every 30 days, for each therapy discipline for which services are provided, a qualified therapist (instead of an assistant) must provide the ordered therapy service, functionally reassess the patient, and compare the resultant measurement to prior assessment measurements.

Inpatient Hospital

Occupational therapy services must be those services that can be safely and effectively performed only by or under the supervision of a qualified physical therapist. Because the regulations do not specifically delineate the type of direction required, the provider must defer to his or her occupational therapy state practice act.

Outpatient Hospital

Occupational therapy services must be those services that can be safely and effectively performed only by or under the supervision of a qualified physical therapist. Because the regulations do not specifically delineate the type of direction required, the provider must defer to his or her occupational therapy state practice act.

Rehabilitation Agency

When a OTA provides services, either on or off the organization’s premises, those services are supervised by a qualified physical therapist who makes an onsite supervisory visit at least once every thirty (30) days or more frequently if required by state or local laws or regulation.

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