Last year, Medicare implemented a policy prohibiting a physician from serving as a “supervisor” for a physical therapy assistant.  Thus, a physician who employed or contracted with a physical therapy assistant to implement a therapy plan under the physician’s direction, would have to contract or arrange for supervision of the assistant by a licensed physical therapist.  Until recently, it was long standing practice that a physician who was physically present in the office suite could use unlicensed personnel to implement the therapy plan developed by the physician for a patient.  The physician, however, remained responsible for the evaluation and re-evaluation of any patient treated in a therapeutic program that was implemented by the unlicensed personnel that the physician was supervising directly.             

            Recently, Medicare implemented a policy change that requires all physical and occupational therapy be performed by “Qualified Personnel.”  Qualified Personnel do not have to possess a state license in either physical or occupational therapy, but essentially must be able to demonstrate equivalent training.  Since licensing laws for these allied health professionals are gradually becoming more restrictive by requiring a Master’s degree or Doctoral degree as a minimal requirement for licensure, this equivalent training requirement for “Qualified Personnel” will be virtually impossible to meet.  Thus, the only way to bill for physical or occupational therapy services provided by individuals who do not meet the criteria for “Qualified Personnel” is for the physician to be physically present in the therapy room when the therapy is being provided and personally supervise the therapy.  If you are concerned how this change may impact your practice, please contact us.