What are the current regulations regarding billing for a student with Medicare Part A residents?
Effective October 1, 2011, which was quite a while ago, line of sight supervision for students for Part A is no longer required. However, if your State Practice Act is more stringent about student supervision, then you need to follow that practice Act. CMS considers a student an extension of the therapist and the student's time is not separately reimbursable. So, while you can put the students minutes on the MDS for Medicare Part A, you as the therapist are supervising that student whether your line of sight or not and that's really what Medicare is paying for, your supervision of that student.
Billing for Students
Individual therapy. When a student is involved with the treatment of one resident at a time, those minutes are coded as individual therapy. The supervising therapist cannot be engaged in any other treatment or activity.
Concurrent therapy. Concurrent therapy involves the treatment of two residents, who are not performing the same or similar activities, at the same time, regardless of payer source. When a therapy student is involved with treatment and one of the following occurs, the minutes may be coded as concurrent therapy:
- The therapy student is treating one resident and the supervising therapist/assistant is treating another resident; or
- The therapy student is treating 2 residents; or
- The therapy student is not treating any residents and the supervising therapist/assistant is treating 2 residents at the same time, regardless of payer source.
Group therapy. The time for a group session may only be counted if the full group of four participants is being run by either the supervising therapist or the student, while the other may not be supervising any other therapists or treating residents. When a therapy student is involved with group therapy treatment, and one of the following occurs, the minutes may be coded as group therapy:
- The therapy student is providing the group treatment and the supervising therapist/assistant who is not supervising other individuals
- The supervising therapist/assistant is providing the group treatment and the therapy student is not providing treatment to any resident.