During a November 15, 2018 Inpatient Rehabilitation Facility (IRF) phone call, a Centers for Medicare and Medicaid Services (CMS) representative stated that according to hospital conditions of participation that Inpatient Rehabilitation Facilities (IRFs) must meet, students do not have a role in providing therapy or therapy minutes to patients, even under direct supervision of the licensed therapist. On December 11, 2018, the American Physical Therapy Association (APTA), American Occupational Therapy Association, and American Speech-Language-Hearing Association participated in a meeting with CMS. During the meeting, CMS indicated that there had been
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