OT/OTA Student Services
Historically, OT and OTA students have
participated in the delivery of occupational therapy
services under the supervision of occupational
therapy personnel in a variety of fieldwork sites.
The changes to Medicare payment systems over the
last few years have brought concurrent changes to
the way in which the Centers for Medicare and
Medicaid Services (CMS), formerly the Health Care
Financing Administration (HCFA), interprets how and
whether the Medicare program should provide payment
for services provided by students. In the article, "Strategies
for Creative Fieldwork Opportunities," AOTA’s
Academic Affairs, Federal Affairs, Practice, and
Reimbursement and Regulatory Policy staff provide
guidance to help occupational therapy programs,
fieldwork sites, and facilities understand and adapt
to these changes.
For those settings that serve Medicare patients,
it is important to be aware of both new and existing
Medicare payment policies. Although Medicare does
not state that students cannot provide services, CMS
has published specific criteria relating to how and
when the program will pay for services provided by
students. When developing fieldwork plans for sites
that serve Medicare patients, two issues must be
considered:
- Whether Medicare payment rules
specifically allow or restrict coverage of
services provided by students, and
- What type and level of supervision are
required to raise those services provided by
students to the level of covered "skilled"
occupational therapy as defined by the
Medicare program.
All relevant Medicare coverage criteria must be
reviewed if reimbursement is sought for services. In
addition, many State practice acts and regulations
provide requirements (legal statutes) and guidance
for occupational therapy services provided by
students. You can find the regulatory board contact
information on the
State-by-State OT Law Database located in the
Licensure section of this Web site.
The following chart sets out for each Medicare
setting whether Medicare payment rules specifically
allow or restrict coverage of services provided by
students and what type and level of supervision
Medicare requires to raise the services provided by
students to the level of covered "skilled"
occupational therapy. Practitioners should take care
to assure an appropriate level of supervision,
whether or not a specific CMS rule regarding
students has been issued.
| Setting/Payer |
|
Medicare Coverage of Services Provided by
Therapy Students |
Type
and Level of Supervision of Student Required |
| Medicare Part A
Hospital and Inpatient Rehabilitation
|
CMS has not
issued specific rules. |
CMS has not
issued specific rules. See relevant state
law for further guidance on supervision for
the services to be considered occupational
therapy. |
|
Medicare Part A SNF |
The
minutes of therapy services provided by OT
and OTA students may be recorded on the MDS
as minutes of therapy received by the
beneficiary. |
Services of OT and OTA students must be
provided in the "line of sight" of the OT.
OTAs can provide clinical supervision to OTA
students; however, if the services are to be
recorded for payment purposes, they must be
performed in "line of sight" of an OT |
| Medicare Part A
Hospice |
CMS has not
issued specific rules. |
CMS has not
issued specific rules. See relevant state
law for further guidance on supervision for
the services to be considered occupational
therapy. |
| Medicare Part B
Partial Hospitalization |
CMS has not
issued specific rules. |
CMS has not
issued specific rules. See relevant state
law for further guidance on supervision for
the services to be considered occupational
therapy. |
| Medicare Part A
Home health |
Regulations
(§484.115) specifically cite definitions for
"qualified personnel", which do not include
students. However, CMS has not issued
specific restrictions regarding students
providing services in conjunction with a
qualified OT or OTA. |
Services by
students can be provided (as allowed by
state law) as part of a home health visit,
when the student is supervised by an OT or
OTA in the home |
| Medicare Part B
Private Practice, Hospital Outpatient,
SNF, CORF, ORF, Rehabilitation agency, and
other Part B providers including home health
agencies when providing Part B services |
Under the
Medicare Part B outpatient benefit, the
services of students directly assisting a
qualified practitioner (OT) are covered when
the type and level of supervision
requirements are met. |
Students can
participate in the delivery of services when
the qualified practitioner (OT) is directing
the service, making the skilled judgement,
responsible for the assessment and treatment
in the same room as the student, and not
simultaneously treating another patient. The
qualified practitioner is solely responsible
and must sign all documentation. |
AOTA continues to work with a coalition of
practitioner organizations to advocate for
additional government support for education of
allied health providers and to develop long-term
solutions to the problems caused by Medicare’s
limitations on reimbursement for student services.
Last Update: 02/26/02
Source:
http://aota.org/nonmembers/area13/links/link02.asp
