Can PT Work Off of an OT Evaluation and Vice Versa?

July 24, 2017
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Rick Gawenda
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I occasionally receive questions asking if a physical therapist can provide physical therapy services to a patient off of an occupational therapy evaluation and plan of care without completing an entirely new physical therapy evaluation and establishing a physical therapy plan of care (or vice versa). This may occur when a patient starts with occupational therapy, but then realize the patient should be seen by physical therapy (or vise versa).

Another example could be a practice or organization that provides lymphedema therapy and have both an occupational therapist and physical therapist certified to provide this treatment. Sometimes an organization or practice may want to switch to one discipline or the other due to a therapist’s vacation, therapist’s schedule or times and days that a patient can attend therapy. So, if the patient starts with physical therapy and you are treating the same diagnosis (just different discipline), can an occupational therapist use that physical therapy evaluation and plan of care to implement occupational therapy treatment or would the occupational therapist need to do a new evaluation and establish an occupational therapy plan of care because you changed from PT to OT (or vice versa)?

A third example could be a patient who is being treated by an occupational therapist (OT) who is a certified hand therapist. The OT will be on vacation for one week and the practice or organization wants to switch the hand patients over to a physical therapist who is also a certified hand therapist. In this situation, can the physical therapist treat the patients of the occupational therapist under the occupational therapy plan of care or would the physical therapist need to perform an initial evaluation and establish a physical therapy plan of care?

The answer to all the above questions is

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  1. Thank you for answering the PT/OT evaluation documentation.
    Now the hardship is to convince management with your print out to follow the regulations.

    I always look forward to your news upgrades even if my employer does not follow the regulations.

  2. Thank you for this! I have often wondered about this since in my hand therapy office we have primarily OTs, but also one PT. We don’t often have patients work with more than one therapist, but depending on their schedule or ours, it happens.

    We bill all under one billing NPI and Tax ID. Would billing for a PT eval with the same dx’s and similar tx plan be an issue after having already billing the OT eval previously? Would we bill a reeval instead?

    1. If this is the first visit with the physical therapist (PT), the PT would bill an evaluation. The PT can’t reevaluate something that they never evaluated. What insurance carriers pay for is payer specific.

  3. I can’t believe how timely this post was for us. For years we have kept our OT, CHT and PT, CHT patients separate and operated as you describe BUT we recently heard from another hospital based therapy program in Michigan that has been having certified hand therapists, regardless of whether they were first OT’s or PT’s, work on the same patient with a prescription that says “OT/PT Hand Therapy”. Their rationale and my thought too is that CHT’s are essentially their own discipline and function under the same ‘scope of practice’. In our EMR, their evaluation pathways are exactly the same. They us the exact same type of evaluative tests/techniques, so I am struggling a bit with this one. Thankfully, we have only done tried this for one patient this vacation season, but

    1. Thank you for the feedback. Please keep in mind that CHT’s are not a discipline. They are a specialty. OT and PT are the disciplines.

  4. Rick, you are exactly on point. The ruling requirement is state licensure but Medicare requires an OT or PT evaluation prior to treatment and that treatment must flow from the discipline specific plan of care. The two professions are not interchangeable. And CHTs can only practice if they are licensed as either an OT or PT and must follow those rules and those of payers. State laws often require an evaluation prior to treatment as well. If administrators are encouraging substitution, AOTA and I am sure APTA would be happy to assist individuals to defend appropriate practice practices. Thanks for the article. Chris Metzler, AOTA Chief Public Affairs Officer

  5. Rick, for your example above regarding filling in for vacation or sickness etc. between disipilines, I am assuming the practice act for a particular state would still be your guide even in a physician owned practice. Is that correct? Or do the rules of billing incident to allow for this to take place?

    1. In a physician owned practice, a PT still can’t work off an OT plan of care and vice versa.

  6. Could a PT perform a Modality, i.e. Dry needling on an OT patient without establishing a plan of care? Currently in the clinic only PT’s are certified in Dry Needling.

  7. For some clarification on the topic of a PT and an OT sharing a Medicare beneficiary with the same diagnosis (example of CHT):

    1. Each discipline would generate their own evaluation and plan of care. Would both disciplines charge for the evaluation? Or would one discipline charge for the evaluation and the other charge ‘treatment codes’?

    2. Would progress notes be combined between both PT and OT (to ensure continuity of documentation from one session to another) or would each document separately – as this affects visit count and 10th visit progress reports?

    1. I will first say I would question PT and OT both seeing the same patient for the same DX solely based on staffing issues. That should never occur. With that said, each discipline must do their own evaluation and Progress Report requirements and timing of them is based on each discipline, not combined disciplines.