The NY-NJ Consortia has been closely monitoring the HCFA rulings on Medicare A and Medicare B billing of student physical therapy services. We would like to
refer you to the following memo in regards to Medicare B:


APTA has received an advance copy of the program memorandum on student
services under Medicare Part B that will be sent to Fiscal Intermediaries
and Carriers on Monday, April 11 and the effective date is April 11, 2001.
Program Memorandum Transmittal AB-01-56 is provided in the form of questions
and answers. The memorandum is similar to a previous draft that the Health
Care Finance Administration shared with the TriAlliance several months ago
which indicated that services provided by students to Medicare Part B
patients are not billable to Medicare. A copy of the transmittal is
included below and will be posted on the APTA web page.


Program Memorandum
Department of Health and Human Services (DHHS)
Intermediaries/Carriers
HEALTH CARE FINANCING ADMINISTRATION (HCFA)

Transmittal AB-01-56

Date: APRIL 11, 2001


CHANGE REQUEST 1498

SUBJECT: Questions and Answers Regarding Payment for the Services of
Therapy Students Under Part B of Medicare

This Program Memorandum (PM) is being issued in the form of questions and
answers to respond to numerous inquiries regarding payment for the services
of therapy students under Part B of the Medicare program.

1. Q. Can services provided by a student be reimbursed under
Medicare Part B?

A. No, services performed by a student are not reimbursed under
Medicare Part B. Medicare pays for services of physicians and practitioners
authorized by statute. Students do not meet the definition of practitioners
listed in §1861 of the statute.

2. Q. Can a physical or occupational therapist assistant serve as
a clinical instructor (CI) for a physical therapist or occupational therapy
assistant student while providing services to a Medicare patient that is
within their scope of work, and performed under the direction and
supervision of the licensed physical or occupational therapist?

A. Physical therapist assistants and occupational therapy
assistants are not precluded from serving as CIs for therapy students while
providing services within their scope of work, and performed under the
direction and supervision of a licensed physical or occupational therapist
to a Medicare beneficiary.

3. Q. Can services provided by a student with the supervising
therapist "in the room" be reimbursed?

A. Only the services of the therapist can be billed to Medicare
and paid. However, the fact that the student is "in the room" would not
make the service unbillable. Medicare would pay for the services of the
therapist.

4. Q. The Current Procedural Terminology (CPT) codes for
Therapeutic Procedure state, "Physician or therapist are required to have
direct (one-to-one) patient contact." What if the provider has some contact
with the patient (e.g., 5 minutes direct patient contact time) and then the
student assumes responsibility for treatment under supervision?

A. The therapist can bill for the direct services he/she
provides to patients under Medicare Part B. Services performed by the
therapy student are not payable under Medicare Part B.

5. Q. Under the Part A Skilled Nursing Facility (SNF) benefit, the
SNF Prospective Payment System allows therapy student services to be counted
toward rehabilitation minutes if provided under "line of sight" supervision
of the therapist.* Does "line of sight" supervision allow Medicare Part B
services to be billed for student services?

A. No. "Line of sight " supervision by a therapist does not
allow student services to be billed. Services of students are not billable
under Medicare Part B.

*Under the SNF Prospective Payment System, payments are based upon the case
mix or Resource Utilization Group (RUG) category that describes the patient.
In the rehabilitation groups, the number of therapy minutes delivered to the patient determine the RUG category. Payment levels for each category are based upon the costs of caring for patients in each group rather than providing specific payment for
each therapy service as is done in Medicare Part B.

6. Q. Can student supervision be provided under Medicare as
"direct supervision" (e.g., on premises and immediately available) rather
than "line of sight," after determining student's readiness by the
therapist? This determination is based on the supervisor's evaluation of
student competence and safety, patient acuity, patient complexity, patient's
functional status and outcomes, and number of visits?

A. No. Services provided by students are not billable under
Part B.

7. Q. How can learning experiences be adequately provided for
therapy students under Medicare if they must always be "in line of sight"
even when:

* The student has been deemed competent in providing therapy or components
of care delivery;

* The student is nearing the completion of a clinical experience; and,

* The student is nearing completion of the program and is evaluated as
competent as an entry-level clinician.

A. As previously stated, services of students are not billable
under Medicare Part B. The Medicare statute does not include a benefit
category for students. This policy applies to all physician and
practitioner groups under Medicare. You may wish to consult with physician
groups about how they structure their training programs.

8. Q. What if a student who is supervised under "line of sight" by
the supervising therapist is treating a patient who is under Medicare Part A
on Friday. On Monday, the patient's coverage changes to Medicare Part B.
How does this affect care provided by the student on Monday?

A. The payment methodologies for Part A and B therapy services
rendered by a student are different. Under the physician fee schedule
(Medicare Part B), Medicare pays for services provided by physicians and
practitioners that are specifically authorized by statute. Students do not
meet the definition of practitioners under Medicare Part B.


The effective date for this PM is April 11, 2001.

Notification of the information in this PM should be published in your next
scheduled bulletin.

These instructions should be implemented within your current operating
budget.

This PM may be discarded after April 30, 2002.

If you have any questions, contact Roberta Epps on (410) 786-4503.

The APTA has a comprehensive list of alternative strategies that might be
helpful in designing a plan for students in your facilities. These ideas can
be accessed at: http://www.apta.org/Education/clinical_edu/Student_Services_and_Medi

In regards to the HCFA ruling on student services for Medicare A patients in
skilled nursing facilities; please refer to the APTA web site at:

http://www.apta.org/Education/clinical_edu/victory

This document indicates that in skilled nursing facilities, student therapy
services may be billed to Medicare A recipients as long as the student
receives 'line of sight' supervision from their clinical instructor.