Current Supervision Requirements of an Assistant

October 13, 2020
Rick Gawenda

In the private practice setting, the Centers for Medicare and Medicaid Services (CMS) requires that the physical therapist (PT) provide direct supervision of the physical therapist assistant (PTA) and that the occupational therapist (OT) provide direct supervision of the occupational therapy assistant (OTA) when the PTA and OTA are furnishing covered services to a Medicare beneficiary receiving outpatient physical or occupational therapy services, respectively. This means the supervising PT or OT must be present in the office suite at the time the service(s) is provided by the PTA or OTA to the Medicare beneficiary.

What providers want to know is has anything changed with the direct supervision requirement as a result of the public health emergency (PHE) due to COVID-19? The simple answer is

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  1. what about supervision for non Medicare insurance patients
    and the use of ATC as rehab assistants in outpatient can they document and bill for treatment ?

    1. This article only addresses Medicare Part B. Whether you can use ATC’s to provide therapy services under the supervision of a PT is state practice act and insurance carrier specific.

  2. There is significant difference between PRIVATE PRACTICE and OUT PATIENT setting at some places in CMS guidelines and some places they use the word PRIVATE PRACTICE and OUT PATIENT interchangeably. Rick, you have done that yourself too. You started the sentence as ” PRIVATE PRACTICE” and went on to change it to OUT PATIENT. Please clarify. THE CMS local contractor says follow the State Licensure requirements for supervision. Can you please clarify with citation of CMS publication- 1. If a difference exist between Outpatient and Private practice as we have seen ( but needing your interpretation) 2. If that is the case if a difference exist regarding supervision regardless of State law.

    1. Please re-read the article. The entire article is based on private practice. The word outpatient is referring to outpatient therapy that is provided in a private practice setting. Outpatient would be different than inpatient therapy services. There is a different in the meaning of outpatient versus the meaning of different practice settings that provide outpatient therapy. Hospitals, SNF’s, rehab agencies, private practice, etc., all provide outpatient therapy. You don’t call a patient receiving PT at a private practice, private practice PT just like you don’t call a patient receiving PT at a rehab agency, rehab agency PT. It’s called outpatient therapy regardless of the practice setting that it is provided at.

  3. Hi Rick,

    In regards to outpatient/private practice, I know Medicare has strict guidelines about PT supervision for a PTA and upon researching the majority of other commercials plans, most plans are pretty clear about their guidelines as well. However, for the plans were the wording is a little ‘gray’, is it your professional opinion to stick with the staffed/onsite PT guidelines? In doing so, you would be covered with no question whether the guideline is definitive or not.


    1. If you have questions concerning the supervision requirements of an assistant, I would recommend you contact the insurance carrier, your state therapy association or both.

  4. Is this extended by the provisions in the final rule? All I can find are references to physician/NPPs. Thanks.

  5. Will a PTA be able to supervise a medicare patient via only telecommunications after the PHE? I doesn’t seem like it from the article. Would that mean that the PT would have to be onsite during all Medicare visits again once the PHE passes?

  6. Do you know where to find this information in the FL state practice act? Sometimes its difficult to find the information you are seeking.

    1. If you have questions about your state practice act, I would recommend you contact your state therapy association.