The enclosed guideline is design to shed light as to the uses and requirements regarding services provided by physical therapy assistants (PTA). Please understand that this guidance is valid as of the date of its publication and that the same is not intended to be legal advice. As the name implies the physical therapist assistants (PTA) are health care professionals who work under the supervision of a Physical Therapist in the provision of modalities selected by the supervising physical therapist. Requirements may change from state to state but usually Physical therapist assistants must complete a two-year training program leading to an associate in science (A.S.) degree or associate in applied science (A.A.S.) degree. The curriculum varies from one institution to another but normally they include core courses in principles of physical therapy, introduction to basic patient care, functional anatomy and kinesiology, and clinical practicum. In Florida, licensure for physical therapist assistants is required. The licensure examination is administered by the Federation of State Boards of Physical Therapy. Physical Therapy Assistants must have an A.S. or A.A.S degree in physical therapist assisting prior to taking the exam. In addition to the exam and in order to maintain their license PTAs must complete twenty-four continuing education hours. Medicare does not credential PTAs but will cover for these services in the physical therapist in private practice (PTPP) setting as long as license and supervision requirements are met. For PTPP, the regulations states that direct supervision must occur in order to bill Medicare for the services provided by anyone other than the PTPP who has the provider number. Direct supervision means that the therapist must be in the same office suite and be immediately available to provide assistance when necessary. Also included is the requirement that the supervising therapist provides at least one billable treatment every tenth visit or 30 days, whichever is the least, when the assistant is providing treatment. Some discussion have endured regarding the validity of a PTA working for a Physician, however the guidelines are quite clear on this subject: A PTA can only work under the DIRECT SUPERVISION of a physical therapist. A physician cannot hire a PTA for any reason, unless there will be a PT present that will supervise the care the PTA administers–even if the physician gives the Rx for rehabilitation or any other treatments. This is out of the PTA’s scope of practice and is not legal. In other words, the services of PTAs and Occupational Therapy Assistants (OTAs) 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 42CFR484.4. The direct supervision requirements for PTPPs ALSO apply to a licensed PT (without their own Medicare provider number) who works for the PTPP. The requirement for the PTPP to provide treatment every tenth visit does not apply when a licensed therapists is providing the care to the patient. However, the PTPP must be on premise when services are being provided (in order to bill the Medicare program). Also remember that you need to look at the State’s Practice Guidelines. If they are more stringent than Medicare’s the Provider must abide by those regulations. These regulations about the PTPP can be found in the CMS IOM (Internet Only Manual) Pub. 100-02, Chapter 15, §230.4 B. www.cms.hhs.gov/manuals/IOM/list.asp Medicare has always indicated, for any site of services, that, if the supervision requirements are not met, then the claim can be denied AND the claim be referred to the regional office for review. This usually leads to denials of claims.