Supervision Requirements of a Physical Therapist Assistant

April 23, 2018
Rick Gawenda


Under Medicare Part B, what are the supervision requirements of a physical therapist assistant in the private practice setting and non-private practice setting (i.e. hospital, skilled nursing facility, rehab agency, CORF)?


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    1. The Medicare program does not require notes written by an assistant be cosigned. If you state practice act requires, then you must follow your state practice act as that is more restrictive than the Medicare program.

  1. Why does Medicare require a PTA in a private practice to be in “direct supervision” when a PTA in home health doesn’t.

  2. Why is there a difference in supervisory requirements for Part B private practice settings versus Non-private practice settings? Are not the treatments the same and the licensure the same for a PTA in both settings?

    1. That has been the requirements from CMS as long as I can remember. It might have to do with the fact that in the private practice setting, you are billing under the NPI of the PT whereas in a nonprivate practice, you are billing under the facilities NPI number.

  3. If a therapist is off for a day and the PTA is seeing their patient under the supervision of another PT who is onsite. Can you bill under the PT who is off or do you need to bill under the PT who is onsite providing the supervision. thanks

  4. I have a private PT practice that bills Medicare Part B as an out patient service. However, we do not have a clinic, we provide our services to the patients in their home, but we are not home health care. We complete standard out patient documentation. Can I have PTs performing Evals/Recerts and PTAs doing daily treatment as they do in a home health care setting? Or do I need to have PTs only providing this service?. I know of other PT practices the same as mine and they are having PTs do Evals/Recerts and PTAs doing daily treatments. I am currently only using PTs, but I would like to know if I could use PTAs or nor. Thank you.

    1. If you are a private practice (this means you submit claims on a 1500 claim to the Medicare program), the therapist must be on the premise when an assistant is treating a Medicare beneficiary. So in your model, you would not want to use PTAs to treat a Medicare patient in their home as an outpatient as the PT would need to be in the home with the PTA. If you know of other private practices using assistants to treat Medicare patients in their homes as outpatients and billing for those services through their private practice, they are in violation of the Medicare regulations.

  5. My understanding that under Part A a PTA cannot treat without a PT on premises. Is this still the guideline?

    1. The Medicare program requires general supervision of an assistant in all settings except for private practice. You also need to look at your state practice act and see what the supervision requirements are of an assistant. Follow the one that is most restrictive.

  6. We are in private practice with PT and PTA on staff. Their schedules mirror each other for supervision. What if the PT has an illness/calls off for a day, should any medicare patients on PTA schedule then be cancelled?

    1. A PT must be on the premise in a private practice setting when the PTA is treating a Medicare beneficiary.

  7. In a private practice setting, does this supervision requirement apply for other non traditional Medicare coverage such as Medicare Advantage, Amerigroup, UHC Medicare Solutions, AARP, etc?

    1. Regarding all other insurance carriers besides traditional Medicare, you would have to check with each one as well as your state practice act regarding the supervision requirements of a physical therapist assistant and follow the one that is most restrictive.