can a PT aide treat ? (Full Version)

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Mercury -> can a PT aide treat ? (July 17, 2003 10:42:00 PM)

Wanted to ask : Is a PT aide allowed to do an entire hands-on treatment session with a patient even if they were under the direct supervision of the PT?

jma -> Re: can a PT aide treat ? (July 18, 2003 12:06:00 AM)

The following was taken from the APTA website:

"Procedural Interventions Exclusively Performed by Physical Therapists HOD 06-00-30-36

The physical therapist's scope of practice as defined by the Guide to Physical Therapist Practice includes interventions performed by physical therapists. These interventions include procedures performed exclusively by physical therapists and selected procedures that can be performed by the physical therapist assistant under the direction and supervision of the physical therapist. Procedures that require immediate and continuous examination and evaluation throughout the intervention are performed exclusively by the physical therapist. Such direct interventions within the scope of physical therapist practice that are performed exclusively by the physical therapist include, but are not limited to, spinal and peripheral joint mobilization/manipulation, which are components of manual therapy, and selective sharp debridement, which is a component of wound management"


The American Physical Therapy Association recognizes the following levels of supervision:

General Supervision: The physical therapist is not required to be on-site for direction and supervision, but must be available at least by telecommunications.

Direct Supervision: The physical therapist is physically present and immediately available for direction and supervision. The physical therapist will have direct contact with the patient during each visit that is defined in the Guide to Physical Therapist Practice as all encounters with a patient/client in a twenty four hour period. Telecommunications does not meet the requirement of direct supervision.

Direct Personal Supervision: The physical therapist, or where allowable by law, the physical therapist assistant, is physically present and immediately available to direct and supervise tasks that are related to patient/client management. The direction and supervision is continuous throughout the time these tasks are performed. Telecommunications does not meet the requirement of direct personal supervision"

Provision of Physical Therapy Interventions and Related Tasks HOD 06-00-17-28

It is the position of the American Physical Therapy Association (APTA) that:

Physical therapists are the only professionals who provide physical therapy interventions. Physical therapist assistants are the only individuals who provide selected physical therapy interventions under the direction and at least general supervision of the physical therapist.

Physical therapy aides are any support personnel who perform designated tasks related to the operation of the physical therapy service. Tasks are those activities that do not require the clinical decision making of the physical therapist or the clinical problem solving of the physical therapist assistant. Tasks related to patient/client management must be assigned to the physical therapy aide by the physical therapist, or where allowable by law, the physical therapist assistant, and may only be performed by the aide under direct personal supervision of the physical therapist, or where allowable by law, the physical therapist assistant. Direct personal supervision requires that the physical therapist, or where allowable by law, the physical therapist assistant, be physically present and immediately available to direct and supervise tasks that are related to patient/client management. The direction and supervision is continuous throughout the time these tasks are performed. The physical therapist or physical therapist assistant must have direct contact with the patient/client during each session. Telecommunications does not meet the requirement of direct personal supervision"

From what I understand, a PT aide should have no contact whatsoever on a patient. I personally would never let an aide touch one of my patients, even if I was in the same room. I teach students what they can do and watch them do it, not aides.


Andrew M. Ball PT PhD -> Re: can a PT aide treat ? (July 18, 2003 7:16:00 AM)

I agree, but I'm a little more flexible on this. Although I don't think that any treatment should ever be performed by an aide without PT contact, some aides are MT's, some are ATC's. Provided that they are not assessing and progressing patients, for example, an MT who is an aide could certainly execute massage, ultrasound, and bodywork/soft-tissue work.


Ron -> Re: can a PT aide treat ? (July 18, 2003 10:11:00 AM)

Be careful this can be a "slippery slope"
You cannot bill for or inform patients that they are recieving "physical therapy" when in fact it is being performed by a non- PT licensed individual. Just because a therapist happens to be in the room while the SKILLED intervention is being performed does not make it physical therapy. We use aides ONLY for set up, and clean up.

jma -> Re: can a PT aide treat ? (July 18, 2003 5:30:00 PM)

I agree with you on this Ron, 100%


mato_tom -> Re: can a PT aide treat ? (July 18, 2003 10:39:00 PM)

actually the CPT codes CAN describe actions performed by an "aide"(aide being any person besides a licenced PT or a licensed PTA under the supervision of a PT).......the CPT codes are most definately not profession specific when considering the 97000 series of a few scenarios a non PT
or non PTA can render any
"PT" intervention (eval, man ther, ther ex , ther act, gait, estim, us, etc.) and the billing provider can get reimbursed for it legally...........

Dr. Ball ...are you saying that LMTs and ATCs should be able to provide services under a PT plan of care? yes or no?

Andrew M. Ball PT PhD -> Re: can a PT aide treat ? (July 19, 2003 4:31:00 PM)

If the LMT or ATC wants to submit to being a PT tech, then there shouldn't be a problem.


prohealth -> Re: can a PT aide treat ? (July 19, 2003 7:32:00 PM)

Aides per medicare guidelines are allowed to do simple/ routine/ non-judgmental patient care as delegated by the PT/ OT, and under 'line of sight'supervision of a licensed PT or OT (note not assistants), as long as allowed by their state boards. The following is a quote from a question/ answer publication on the CMS website ( in reference to RAIs for SNFs.

prohealth -> Re: can a PT aide treat ? (July 19, 2003 7:38:00 PM)

Oops the last message went in complete. Here is the quote from the CMS site referred earlier.
Health Care Financing Administration Long Term Care Resident Assessment Instrument Version 2.0 Question and Answers
August 1996
133: We're dealing with the issue of whose time to include for therapy. Under what circumstances would time spent by a Rehab Aide be captured as therapy time in Section P1b.?

A: First, note that the MDS 2.0 measures the resident's characteristics and services received. It is not a tool to report "staff effort." The amounts of time reported in Section P1b must be the "resident's" time in treatment. Regarding Physical and Occupational Therapies, Aides cannot independently provide a skilled service, therefore, if there is not a licensed person supervising the Aide, it should not be counted as therapy. Speech Therapy does not currently recognize an Assistant or an Aide as providing "treatment services". Occupational and Physical Therapies credential Assistants and do allow Aides to be supervised by either licensed staff (including contractors), but both Occupational and Physical Therapies, in their professional standards, require that Aides receive intense supervision and therefore, an unsupervised service provided by a licensed Aide should probably be included under Nursing Rehabilitation/Restorative Care in Section P3, rather than under Therapies in P1b. Even when included in Section P3, the Aide providing the service should be supervised.

Mercury -> Re: can a PT aide treat ? (July 19, 2003 11:01:00 PM)

With the rigorous training that we get in PT school , I personally would not hand over a patient to an aide for the entire Tx sessin regardless of supervision.

Ron :
Thnks for your input. Do you know where I can find supportive documentation for your posting ? Thing is I am discussing this issue with another PT and want to show proof for my stand. I did lookup laws and regulations and came up with : "The PT shall assign only those patient related tasks that can be safely and effectively performed by an aide.The PT shall provide continuous and immediate supervision of the Aide" .(There was some more stuff but I thought this was a key statement).
Doesnt this sentence imply that its Legal for an aide to treat hands-on under supervision ??

goodlooks58 -> Re: can a PT aide treat ? (July 19, 2003 11:51:00 PM)

I would certainly not want a PT aide to do complex ROM movements with any post-op patients, or any sort of spinal mobilization, however, in my judgement, doing ultasound/other modalities and occasionally doing some simple massage techniques to relax a muscle spasm before I as a PT would do my own mobilization or specific soft tissue perfectly ok. In my case I am always watching over my aide as I come into the treatemnt phase to do my "special" technique with every patient. Patients definitley get their money's worth with a "full" treatemnt! There are PTs out there who are absolutists, however, it good to keep an open mind. And regarding charging: Patient and my staff knows that I, as a PT, and the main treater is in charge of his/her care.

prohealth -> Re: can a PT aide treat ? (July 20, 2003 11:04:00 AM)

Mercury- as you already quoted, it is legal. The ethical component comes in on what is being delegated to the aides.

The requirements of supervision and allowance for aides to treat are the same for Medicare; whether or not it is an outpatient setting or, a SNF. However, note that Medicare does require you to follow the state law you are practicing in, if that's more stringent. (Certain states do not allow any treatments by aides. E.g: California & Ohio does for PT, but the Ohio OT Board does not allow OT aides to treat at all). Also, I have seen certain insurances requiring that therapies be provided by licensed therapists alone, and not even assistants ( PPOs) for independent practices. Actually, even the supervision laws for assistants in PTIPs/ OTIPs is also lot more restrictive. Even assistants need 'on-site' supervision in these clinical settings.

I agree with all that the delegated tasks must be simple, routine, needing no judgments calls, and certainly not for a whole session (probably no more than 25% of the session, and delivered under 'direct supervision' obviously.

mato_tom -> Re: can a PT aide treat ? (July 20, 2003 3:43:00 PM)

SJ...your right about the CPT codes...I was referring to a physicians ability to use anybody with a pulse to render "PT" services and bill for them........

Dr Ball........when it comes to matters of services being furnished by a PT or under a PT POC it does not matter what a LMT or ATC wants to submit matters what the individual PT and the state laws and the payors rules allow..........

healthsouth is a good case study.....they ALLEGEDLY used techs(NON PT non PTA) to provide billed treatments to medicare beneficiaries........

if true was this unethical?

if you subscribe to the APTA code of ethics, yes.....personally its up to you

was it illegal?

some states may allow the use of techs,,,some do not...if not, state laws were broken by the delegating therapist....should the therapist be punished by the licensing board of the state?

was it fraud? if proven true then yes it is fraud......

perhaps an even more important question is..... should we be fighting to relax some of the rules regarding delegation of PT duties by a PT....

prohealth -> Re: can a PT aide treat ? (July 21, 2003 9:24:00 PM)

Alright guys, on further investigation it seems that the requirements for Part A and Part B medicare coverage does differ when it comes to use of aides. This has been clarified on the CMS site just recently.

Here is the quote from "Advance for Directors in Rehabilitation":
The regulations covering Part A and Part B are quite different and the Center for Medicare and Medicaid Services (CMS) is working to clearly define the differences between the two. CMS hasn?t changed the regulations for Medicare Part A services, but has recently clarified the position of the aide under Part B. If you look at the references for this answer on the CMS Web site for the question, you?ll see that they refer to:

(a.) The Code of Federal Regulations for the definition of qualified personnel; the section referenced relates to the definitions for specialized providers and refers to Outpatient Physical Therapy (OPT) services and therefore Part B;

(b.) The Medicare Carrier Manual that only refers to Part B services.

With regard to Part A, SNF services, the regulations are contained in the Federal Register, Final Rule, July 30, 1999. According to this document, the services of an aide being supervised by a licensed therapist can be included as minutes of services as, under the Prospective Payment System (PPS) Medicare is paying a per diem rate established from an assessment period and not for the therapist's time.

To summarize Medicare and rehabilitation aide time: In Part A SNF under PPS, the minutes of the aide can be used as minutes of services both in and outside of the assessment reference period provided that the aide is under the direct line-of-sight of the supervising therapist (not therapist assistant) and the therapist is able to adequately supervise the aide during the treatment. For Part B Outpatient, Medicare is paying for the time that qualified personnel provide services as defined through the billing of the HCPCS codes. Medicare is reimbursing for the time and knowledge of the therapist and therapist assistant as defined in the Code of Federal Regulations and an aide doesn?t meet those requirements.

Code of Federal Regulations. Title 42.

HCFA. (June, 2000). Carrier manual. Washington, DC: Dept. of HHS. (Publication 14).

Department of Health and Human Services. (July 30, 1999). Medicare program; prospective payment system and consolidated billing for skilled nursing facilities-update; final rule and notice. Federal Register, 64(146), 41643-41683.

Pauline Watts, MCSP, PT, and Danna D. Mullins, MHS, PT

Mercury -> Re: can a PT aide treat ? (July 21, 2003 10:11:00 PM)

Pauline Watts and Danna Mullins :

Many thanks for getting to the heart of the matter and simplifying things.

Also a big Thnk U to all who pitched in.Appreciate your time and effort !

[This message has been edited by Mercury (edited July 21, 2003).]

coloradojulie -> Re: can a PT aide treat ? (July 22, 2003 5:00:00 PM)

There is a chiropractic wellness center in our area that employs a PTA but has no physical therapist on staff. The aide practices as a physical therapy aid and gives clients the perception that he is providing physical therapy and may also be a physical therapist. About a year ago I wrote him a letter letting him know that he should be careful how he presents his services etc.

According to this issue, can he use his credentials in this situation? Can he practice without the supervision of a physical therapist? Can the chiro bill as if physical therapy were performed? I think no to all of the above, but perhaps there is more information.

My next step is a letter with statutes and a warning that if this practice continues we will report him to the state board.

prohealth -> Re: can a PT aide treat ? (July 22, 2003 9:04:00 PM)


You are welcomed...I was just quoting Pauline & Dana from one of their columns. But I am sure, had they been following this forum, they would have been more than happy to help.

Also Colaradojulie, in my opinion, it would have been okay if the PTA was actually working as a chiropractic assistant( I don't believe there is a licensure requirement for a CA)and his services were billed under the chiropractor's UPIN. Since, HCPCS/CPT codes are not discipline specific, I believe legally the chiropractors can use them and get reimbursed as long as it's allowed per their state practice act. I believe codes such as therapeutic exercises, neuromuscular re-education, selfcare management, manual therapies, the modalities U/S, E-stim, etc. are common to PT/OT/DC.

The fact that the PTA or PT aide can only be supervised by a PT and services rendered must be under a PT, this certainly seems an infringement.


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