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CMS will not require additional information to the notes, it is already expected that the provider be identified, and the time tracked.
CMS has clarified that it is expected the documentation in the medical record to be sufficient to know whether a specific service was furnished independently by a therapist or a therapist assistant, or was furnished “in part” by a therapist assistant, in sufficient detail to permit the determination of whether the 10 percent standard was exceeded.
84 FR 40482
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