News Alert: CMS: Clarifies Counting of Student Therapy Minutes

IRFs can breathe easier; no change in policy.

CMS has clarified the question of counting minutes of therapy provided by students.

The Inpatient Rehabilitation Facility (IRF) world reacted in shock to an unexpected statement made during a November Medicare Learning Network call wherein a Centers for Medicare & Medicaid Services (CMS) staffer responded to a listener’s question related to counting minutes of therapy provided by a therapy student with guidance that these minutes would not count, regardless of the level of supervision.  

Following that call, the therapy professional associations –the American Physical Therapy Association (APTA), American Occupational Therapy Association (AOTA), and the American Speech and Hearing Association (ASHA) –- requested a meeting with CMS to address their concerns.

During the meeting on Dec. 11, CMS representatives indicated that there had been no change in policy related to the provision of therapy services – and, more importantly, related to student participation – during 2018. In a follow-up letter to the associations earlier this week, CMS clarified that its current policy does not prohibit therapy services furnished by a therapy student, under the appropriate supervision of a qualified therapist or therapy assistant, from counting toward the intensive rehabilitation therapy program.

As IRFs breathe easier about this issue, it’s important to remember the following:

  • As we stated in our earlier article, Medicare Learning Network programs are designed to provide information, and not to set policy. There have consistently been CMS clarifications following training programs in response to questions from the field and responses to those questions.
  • IRFs should have clear policies on the involvement of students in patient care, along with clear descriptions of the supervision requirements.

Program Note:

 Angela Phillips will report this story on Monitor Monday, Jan. 14, 10 a.m. ET.


Angela Phillips, PT

Angela M. Phillips, PT, is President & Chief Executive Officer of Images & Associates. A graduate of the University of Pennsylvania, School of Allied Health Professions, she has almost 45 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting Inpatient Rehabilitation Facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

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