Physical Therapists/Occupational Therapists (PTs/OTs)

An individual is eligible to enroll as an independently enrolled therapist if he/she is either a PT or an OT as defined in this chapter and not an employee of a hospital, Critical Access Hospital (CAH), SNF, home health agency, hospice, CORF, physician clinic, Community Mental Health Center (CMHC), a rehabilitation agency, or public health agency.

An independently enrolled therapist must maintain a private office even if services are furnished in a patient’s home. A private office is space that is leased, owned, or rented by the practice and used for the exclusive purpose of operating the practice. For example: an independently enrolled therapist may not furnish covered services in an SNF. Therefore, if a therapist wishes to locate his/her private office on-site at an NF, the private office space may not be part of the Medicare participating SNF space and the therapist’s services may be furnished only within the therapist’s private office space.

Occupational Therapists (OTs)

An individual is eligible to enroll as an OT if he/she maintains applicable State licensure or is in compliance with State regulatory requirements in states that do not license.

OTs employed by outpatient hospitals, SNFs, CORFs, physician clinics, Medicare-certified rehabilitation agencies, IHS, or RHCs may enroll with PrimeWest Health. To enroll with PrimeWest Health, OTs must comply with the requirements of MN Rules part 9505.0195 and must be enrolled by Medicare.

Physical Therapists (PTs)

An individual is eligible to enroll as a PT if he/she meets the following requirements:

1. Maintains applicable State licensure requirements or is in compliance with State regulatory requirements in states that do not license
2. Graduated after successful completion of a PT education program accredited by the Commission on Accreditation in Physical Therapy Education (CAPTE), or its equivalent
3. Passed an examination for PTs approved by the State in which the PT services are provided

PTs employed by outpatient hospitals, SNFs CORFs, physician clinics, Medicare-certified rehabilitation agencies, IHS, or RHCs may enroll with MHCP. To enroll with MHCP, PTs must comply with the requirements of MN Rules part 9505.0195 and must be enrolled by Medicare.

Physical Therapist Assistants (PTAs) and Occupational Therapist Assistants (OTAs)

PrimeWest Health reimburses providers for the services of a PTA or an OTA when services are provided under the direction of a PT or OT. The PT or OT must provide on-site observation of the treatment and documentation of its appropriateness at least every sixth treatment session when the PTA or OTA provides services. PTs/OTs will not be reimbursed for PTAs/OTAs providing evaluations or re-evaluations.

MHCP reimburses providers for the services of a PTA or an OTA when services are provided under the supervision of a qualified therapist as indicated below.

PTA

PTAs must do the following:

1. Have successfully completed all academic and field work requirements of a PTA program accredited by the Commission on Accreditation in Physical Therapy Education
2. Maintain State licensure requirements or be in compliance with State regulatory requirements in states that do not license PTAs

Supervision of a PTA

A qualified PT must provide on-site observation of the treatment and documentation of its appropriateness at least every sixth treatment session when services are provided by a PTA. A PT may delegate patient treatment procedures only to a PTA who has sufficient didactic and clinical preparation. The PT may not delegate the following activities to the PTA or to other supportive personnel: patient evaluation or reevaluation, treatment planning, initial treatment, change of treatment, and initial or final documentation. A licensed PT may supervise no more than two PTAs at any time.

OTA

OTAs must do the following:

1. Be certified by the National Board for Certification of Occupational Therapy as an OTA
2. Must maintain applicable State licensure requirements or be in compliance with State regulatory requirements in states that do not license OTAs

Supervision of an OTA

An OT must determine the frequency and manner of supervision of an OTA performing treatment procedures based on the condition of the member, the complexity of the treatment procedure, and the proficiencies of the OTA.

Face-to-face collaboration between the OT and the OTA must occur, at a minimum, every two weeks, during which time the OT is responsible for the following:

1. Planning and documenting an initial treatment plan and discharge from treatment
2. Reviewing treatment goals, therapy programs, and member progress
3. Supervising changes in the treatment plan
4. Conducting or observing treatment procedures for selected members and documenting appropriateness of treatment procedures. Members will be selected based on the OT services provided to the member and the role of the OT and the OTA in those services
5. Ensuring the service competency of the OTA in performing delegated treatment procedures

Face-to-face collaboration must occur more frequently than every two weeks if necessary to meet the above requirements.

Evaluations and reevaluations will not be reimbursed if provided by OTAs.

The OT must document supervision compliance in the member’s file or chart.

Speech-Language Pathologists (SLPs)

SLPs, as defined in this chapter, are eligible to enroll as independent providers if they maintain an office at their own expense. An individual completing the clinical fellowship year required for certification is not eligible to enroll as an independent SLP. An individual is eligible to enroll as an SLP if he/she meets the following requirements:

1. Maintains applicable State licensure requirements or is in compliance with State regulatory requirements in states that do not license
2. Has a Certificate of Clinical Competence in speech-language pathology from the American Speech-Language-Hearing Association, or is completing the clinical fellowship year required for certification as an SLP

SLPs employed by outpatient hospitals, SNFs, CORFs, physician clinics, Medicare-certified rehabilitation agencies, IHS, or RHCs may enroll with PrimeWest Health.

Speech-Language Pathology Assistants (SLPAs)

A speech-language pathology assistant (SLPA) must satisfactorily complete either of the following education requirements:

1. An associate degree from a speech-language pathology assistant program that is accredited by the Higher Learning Commission of the North Central Association of Colleges or its equivalent as approved by the commissioner
2. A bachelor's degree in the discipline of communication sciences or disorders with additional transcript credit in the area of instruction in assistant-level service delivery practices and completion of at least 100 hours of supervised fieldwork experience as a speech-language pathology assistant student

Delegated duties

A speech-language pathology assistant may perform only those duties delegated by a licensed speech-language pathologist and must be limited to duties within the training and experience of the speech-language pathology assistant.

Duties may include the following as delegated by the supervising speech-language pathologist:

1. Help with speech-language and hearing screenings
2. Implement documented treatment plans or protocols developed by the supervising speech-language pathologist
3. Document member performance
4. Help with assessments of members
5. Help with preparing materials and scheduling activities as directed
6. Perform checks and maintenance of equipment
7. Support the supervising speech-language pathologist in research projects, in-service training, and public relations programs
8. Collect data for quality improvement

Prohibited services

A speech-language pathology assistant may not do any of the following:

1. Perform standardized or non-standardized diagnostic tests, perform formal or informal evaluations, or interpret test results
2. Screen or diagnose clients for feeding or swallowing disorders, including using a checklist or tabulating results of feeding or swallowing evaluations, or demonstrate swallowing strategies or precautions to members or the members' families
3. Participate in parent conferences, case conferences, or any interdisciplinary team without the presence of the supervising speech-language pathologist or other licensed speech-language pathologist as authorized by the supervising speech-language pathologist
4. Provide member or family counseling or consult with the member or the family about the member status or service
5. Write, develop, or modify a member's individualized treatment plan or individualized education program
6. Select members for service
7. Discharge members from service
8. Disclose clinical or confidential information either orally or in writing to anyone other than the supervising speech-language pathologist
9. Make referrals for additional services

A speech-language pathology assistant must not sign any formal documents, including treatment plans, education plans, reimbursement forms, or reports. The speech-language pathology assistant must sign or initial all his/her own treatment notes.

Supervision requirements

A supervising speech-language pathologist must authorize and accept full responsibility for the performance, practice, and activity of a speech-language pathology assistant.

A supervising speech-language pathologist must meet the following:

1. Be licensed under Minnesota Statutes 148.511 – 148.5196
2. Hold a certificate of clinical competence from the American Speech-Language-Hearing Association or its equivalent as approved by the commissioner
3. Have completed at least one continuing education unit in supervision

Supervision of an SLPA

A qualified speech-language pathologist must supervise a speech-language pathology assistant according to the following schedule:

1. For the first 90 work days, the SLP must supervise 30 percent of the work the SLP assistant performs within a 40-hour work week, and must directly supervise* at least 20 percent of the work.
2. For the work period after the initial 90-day period, the SLP must supervise 20 percent of the work the SLP assistant performs within a 40-hour work week, and at least 10 percent of the work performed must be under direct supervision*

* Direct supervision must be on-site, in-view observation and guidance by the supervising speech-language pathologist while the SLPA is performing a delegated duty. The supervision requirements described in this section are minimum requirements. The supervising speech-language pathologist may impose additional supervision requirements.

A supervising speech-language pathologist must be available to communicate with a speech-language pathology assistant at any time the assistant is in direct contact with a member.

A supervising speech-language pathologist must document activities the assistant performs that the supervising speech-language pathologist directly supervises. At a minimum, the documentation must include the following:

1. Information about the quality of the speech-language pathology assistant's performance of the delegated duties
2. Verification that any delegated clinical activity was limited to duties the speech-language pathology assistant is authorized to perform under this section

A supervising speech-language pathologist must review and cosign all informal treatment notes signed or initialed by the speech-language pathology assistant.

A full-time speech-language pathologist may supervise no more than one full-time speech-language pathology assistant or the equivalent of one full-time assistant.

Notification

Any agency or clinic that intends to use the services of a speech-language pathology assistant must provide written notification to the member or, if the member is younger than 18 years old, to the member's parent or guardian before a speech-language pathology assistant may perform any of the duties described in this section.

Private Practice Therapists (PPT)

Occupational therapists, physical therapists, speech-language pathologists, and audiologists are considered in private practice if they maintain a private office space at their own expense and provide services in that space or in a member’s home.

Alternatively, a private practice therapist (PPT) may be employed by another supplier and furnish services in facilities provided at the expense of that supplier.

A private office is space that the practice leases, owns, or rents and uses for the exclusive purpose of operating the practice. For example, a private practice therapy practitioner may not furnish covered services in a skilled nursing facility (SNF). If a private practice therapy practitioner wishes to locate his/her private office on-site at a nursing facility, the private office space may not be part of the Medicare-participating SNF space and the therapist may provide services only within the therapist's private office space.

Private practice also includes therapists who are practicing therapy as employees of another supplier, professional corporation, or other incorporated therapy practice. Private practice does not include individuals when they are working as employees of an institutional provider.

Therapy Students Providing Care

Only the direct one-to-one patient contact services of the qualified therapist as defined in this section are billable when a student is involved in the delivery of services. PrimeWest Health does not reimburse for services a student performs even if the student provides the service under “line of sight” supervision of a qualified therapist. Qualified therapists may bill and be paid for providing services in the following scenarios:

1. A qualified therapist is present and in the room for the entire session. The student participates in the delivery of services when the qualified therapist is directing the treatment, making the skilled judgment, and taking responsibility for the assessment and treatment.
2. A qualified therapist is present in the room guiding the student in service delivery when the therapy student is participating in providing services, and the therapist is not engaged in treating another patient or doing other tasks at the same time. Documentation of the therapy service must clearly indicate the qualified therapist was present in the room, guiding the student in the delivery of the service(s) and not simply “on the premises.” The focus of the therapist must be on the services the student is providing and not on other activities or other patients.
3. The student may complete the documentation as part of his or her education or hands-on training, but the qualified therapist is responsible for the delivery of services and the documentation and must sign all the documentation. In signing the documentation, the therapist indicates he or she has read it and is responsible for its contents. Documentation must clearly indicate the student provided the services under the therapist’s direction. The student may also sign the documentation but it is not required for payment.

PTs with a valid temporary permit (MN Stat. sec. 148.71) to practice and OTs with a valid temporary license (MN Stat. sec. 148.6418) to practice may provide services under the supervision of a licensed PT/OT, but may not enroll as PrimeWest Health providers.