Does Medicare Recognize Direct Access

November 12, 2018
Rick Gawenda

Lately, I have been receiving questions regarding the Medicare program and does the Centers for Medicare and Medicaid Services (CMS) recognize and pay for direct access for outpatient therapy services. In CMS Publication 100-02, Chapter 15, Section 220.1.1, CMS states “Although there is no Medicare requirement for an order, when documented in the medical record, an order provides evidence that the patient both needs therapy services and is under the care of a physician”. So does this mean the Medicare program recognizes and pays for Direct Access since a physician order is not required?

The answer is

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  1. If the patient is seen for an evaluation and he doesn’t have a physician’s order, but follow-up visits are not required, are we still required to obtain a physician’s signature to fulfill Medicare’s certification requirement?

    1. If you have no physician order to perform the evaluation, you would need the plan of care signed by the physician. If you had a physician order and only bill an evaluation and no other treatment codes, the order would suffice for the evaluation. If you billed an evaluation and treatment for a one time visit, a plan of care signed by the physician or NPP would be required.

  2. We have had instances of a provider modifying the therapist’s POC. Examples would be not allowing the treatment to include functional dry needling or limiting the number of visits to say 6. Are we then bound to these limitations?

  3. When will doctors of physical therapy ever fight to take their place as primary practitioners of physical therapy? WHY MUST A DOCTOR OF PHYSICAL THERAPY BE REQUIRED TO HAVE AN MD OR WORSE, A NON PHYSICIAN REFERRER, CERTIFY THE THERAPIST’S PLAN OF PHYSICAL THERAPY CARE ??????? Would love to hear what others think. Am I the only one with this contention?

  4. I fully agree. However, I have therapists who have an aversion to using or being called Dr. and until that changes why would the above change. We need to be assertive in our skills.

  5. I see as Physical therapy degree from old school or recent program as doctorate as wasted? cuz we still have to have orders from a physicians. Care givers or baby sitters could do same as following orders and they dont have extensive education as like us…
    So… who are we as PT or DPT ??

  6. DPT…do you allow your therapists to refer to themselves as “doctors”. I personally think that confuses the public and potentially dangerous. Case in point. I have one DPT that continues to do it (I tell my therapists to use DPT) and the only site of my 10 that patients routinely call for refills or looking for medication. What if a cancerous tumor or other medical condition is the cause of pain and care was delayed 6-8 weeks as they receive their course of therapy. Would the DPT be covered legally if referring to themselves this way? Still a bit sticky for me. But I am an OT and do not agree with our profession moving closer to OTD.