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,

Please give an example of something that could only require the skill of

an aide therefore should only be done by an aide. Other than

transportation and photocopying, I regularly do " aide " tasks out of

necessity. (and sometimes I even do copies and transport too). I think

it could be a dangerous thing to set up parameters of tasks that should

only be done by an aide. When our 1 aide is sick we do all of her work

along with ours! If you promote this idea that cartain tasks require no

more skill than an unlicensed aide, why would insurance pay at all??

They will say, you could teach the family to do this at home. Slippery

slope I say!!

PT

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; Oh my! I think I have confused you about the point I was

trying to make! I would not want to be interpreted as advocating or

even suggesting that there are certain activities that " could only

require the skill of an aide, therefore should only be done by an

aide " .....I think I was trying to argue the opposite indeed! What I was

saying is that; if we argue that the quality (e.g. effectiveness, and

efficacy) of a particular intervention/procedure is the same regardless

of the personnel providing it, and therefore should be reimbursed at the

same level....then I worry we could not afford to provide that

intervention except when done by the lowest level skilled/knowledgeable

level personnel we can. Let me see if I can state it a different way.

If we believe that reimbursement should be based on the

procedure/intervention done (assuming that delegation and supervision

have been consistent w/standard of care), because the level of skill and

knowledge necessary to do that procedure /intervention are nonvariable,

and the results of providing it are highly predicable....then yes,

reimbursement should be the same. But do we really believe this? Is it

really true? Sure you might say, a hot pack is a hot pack....ultrasound

is ultrasound. But is there a difference between the US when an aide is

asked to give US to that patient's shoulder, and when a P.T. does US to

the same shoulder? When I use US on say a shoulder w/adhesive

capsulitis, besides making certain to following the basic

technique....I'm positioning, maybe stretching, repositioning,

continually assessing it's effectiveness as I'm doing it (I'm I getting

a better stretch, should I increase the cross-chest adduction more to

increase the effect am I getting the best exposure to the insertion of

the....etc. etc.....)....is the aide doing the same? Or is it more

likely that the aide is doing " US x 5 min to the posterior shoulder at

1.5 w/cm2 " ......which would you be willing to pay more for? Sure, we

have clearly stated things that only a PT can do as the minimum skill

level for that procedure...evaluation, reevaluation, treatment planning,

discharge planning, and that's why those activities should always (we

would hope) be reimbursed at the highest levels. But conversely if

we've argued that the reason we should get the same reimbursement when

the intervention is delegated vs. when done by the P.T. then

reimbursement will be set at the lower level, and we won't be able to

afford doing it ever at the highest level of skill. At my facility I

try really hard not to have to have my clinical staff (e.g. licensed PTs

and OTs) doing photocopying, whirlpool cleaning, hot pack assembling

etc. (unfortunately, not as successfully as I wish), so that they're

spending the bulk of their time doing professional activities. What I

cringe at is the situation where the P.T. is cleaning the booth because

the aide is busy doing the exercise class or the US, and I fear this

happens all to frequently. The result has been I fear that we can no

longer consistently afford to have the P.T. do the US in the situation

when more is needed than " 1.5w/cm2.... " because we haven't ourselves

done a good job distinguishing the difference.....

I fear we've made the bed we're now sleeping in.......

Arslanian, MS,PT

Brigham & Women's Hospital

> Re: student documentation

>

> ,

>

> Please give an example of something that could only require the skill

> of

> an aide therefore should only be done by an aide. Other than

> transportation and photocopying, I regularly do " aide " tasks out of

> necessity. (and sometimes I even do copies and transport too). I

> think

> it could be a dangerous thing to set up parameters of tasks that

> should

> only be done by an aide. When our 1 aide is sick we do all of her

> work

> along with ours! If you promote this idea that cartain tasks require

> no

> more skill than an unlicensed aide, why would insurance pay at all??

> They will say, you could teach the family to do this at home.

> Slippery

> slope I say!!

>

> PT

>

>

>

> ----------------------------------------------------------------------

> --

>

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Guest guest

:

I completely agree with your point that we are seeing the other professions follow the Physicians in Health Care reform. I too have felt this way for quite a while now. I think that we should take note of this and use it wisely, hence my points about delegable tasks. We have seen, for example, the trend away from specialization toward primary care in medicine. We know that this is a priority for other professions as well and behooves us to be prepared.

I feel strongly that we need to place more emphasis on specialization as one of advanced competence rather than simply practice preference. I have heard one too many therapists (PT, OT and SLP) refer to themselves as being an XYZ specialist simply because they " like working with " the XYZ patient. I also feel that some have made a grave mistake in classifying their clinical expertise by setting. I have a hard time accepting that there is such thing as a sub-acute or acute care therapist. These are phases of recovery, and if our expertise is confined to one phase of recovery, the term " overspecialized " does not even come close to describing this absurdity.

If I know how to treat a patient with primary diagnosis of stroke today in Acute Care, I had better know how to treat them tomorrow in Sub-Acute, or Outpatient, or wherever. If I don't, then I will not be much help to the patient, or be very valuable. " Specialization " in a setting involves managerial, regulatory, accreditation issues etc., not clinical. The patient is the same patient that was in another setting yesterday. They are simply one more day into their recovery.

One of my favorite stories is of a PT colleague of mine who went to speak with a Subacute Rehab program about a position. He was asked if he had any experience in sub-acute to which he responded, " No, but I know how to treat your patients! " . Needless to say, he was not offered a position. I don't know about the rest of you, but I think this guy hit it right on the head. We have allowed ourselves to become specialists in reimbursement manipulation rather than patient management. And to that I say, shame on us. We had better quickly see the trends developing and anticipate our next move or........

Ken Mailly, PT

PAR

aptanj

President

Mailly Consulting Inc./RPA

Re: student documentation

Once again, PT is following the physicians in healthcare reform. It use to be one attending could bill for many residents doing surgery at one time on their service, i.e. plastics, ortho, etc. The attending did not have to be in direct supervision or in the case of senior or chief residents in the building. That is now considered fraud. The attending has to be in direct supervision to bill for services. Same holds true for emergency room and anesthesia. This hurt many of the large teaching hospitals and particularly the rural hospital that depended on resident help to cover patients and generate revenue. It decreased the incentive for facilities to offer resident positions which has become a problem in some specialties. My question: Is that what will happen to us next? Are we going to have more difficulty finding affiliations for our students if they don't generate revenue?

Lundy, MS,PT,PCS

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Guest guest

:

" I fear we've made the bed we are now sleeping in. "

or the house we have built!

The Carpenter

Re: student documentation

> > ,

> > Please give an example of something that could only require the skill

> of

> an aide therefore should only be done by an aide. Other than

> transportation and photocopying, I regularly do " aide " tasks out of

> necessity. (and sometimes I even do copies and transport too). I

> think

> it could be a dangerous thing to set up parameters of tasks that

> should

> only be done by an aide. When our 1 aide is sick we do all of her

> work

> along with ours! If you promote this idea that cartain tasks require

> no

> more skill than an unlicensed aide, why would insurance pay at all??

> They will say, you could teach the family to do this at home.

> Slippery

> slope I say!!

> > PT

> > > > ----------------------------------------------------------------------

> --

>

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Guest guest

Actually , it was the interpretation and Medicare's clarification of the

term " direct supervision " that changed the standard of practice. Which also

seems to be happening to us now.

Lundy, MS,PT,PCS

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wrote:

Original Article: /list/ptmanager/?start=4487

> The most recent newsletter from the Pennsylvania Physical Therapy

> Association states in print on page 26

>

> " Medicare will not pay for treatment to their beneficiaries by PT

> or PTA students. This decision is a strict interpretation of existing

> regulations. Physical Therapy must be provided by licensed individuals

> and the students are not. Students can watch and assist, but they cannot

> be the primary, direct caregiver for a Medicare patient. In this

> situation, they should function as aides. "

>

> Are others familiar with this? Where can I find this " interpretation " ?

> How are you handling this in your clinic?

>

> I personally can not imagine going through all of my clinical training and

> not working with the elderly. I learned so much from them! And I

> certainly would have been opposed to paying for my clinical education if I

> were going into a clinic to " function as aides " .

>

> Please advise. Thank you.

>

> Janet Moffitt Exley, PT, Director

> University of Pittsburgh at Titusville

> PTA Program

>

I am the ACCE at a Southeastern University This issue has been raised several

times by my clinics over the past year. I had been unable to get much

information about this. I finally tracked down Jim Nugent at Reimbursment at

APTA last week. His " interpretation " is that these denials are a result of the

recent enforcement of a longstanding Medicare reg that requires caregivers to be

" employees " of a clinic, which students are not. He also tells me that this

applies only to PTIP's (Physical Therapist Independent Practioners) If any of

you have substantiated information to the contrary, I would certainly like to

know!

>

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The following statement is an official response from staff at APTA related

to the question regarding students and Medicare reimbursement , relayed to

the list by

, PT

Treasurer, APTA Board of Directors

davidperry@...

Clinical Education and Medicare

Several questions have arisen recently regarding Medicare reimbursement for

students, an issue which the Medicare law and regulations do not

specifically address. For physical therapists in private practice (PTPP),

Medicare requires that services be furnished by employees of the therapy

office and that those employees be supervised by the physical therapist.

APTA is aware that, because students are not considered employees, a

Medicare carrier in one state wrote letters informing some PTPPs that they

would not receive Medicare reimbursement for the services furnished by the

students in the PTPP setting.

With regard to the prospective payment system (PPS) for skilled nursing

facilities (SNF's), the Health Care Financing Administration (HCFA) has not

published any specific statements concerning the status of students or

concerning reimbursement for their services. Informally, HCFA staff has

indicated that the Balanced Budget Act has required no change in HCFA policy

regarding the treatment of student services. It is APTA's understanding that

Medicare considers students to be aides because they do not meet the

Medicare definitions of physical therapists or physical therapist

assistants. This understanding is derived from a HCFA statement in response

to comments on the Salary Equivalency regulation.

APTA also has heard verbally from HCFA staff that Medicare will allow the

time of services provided by aides in the SNF setting to count as

rehabilitation minutes for the purpose of placing the patient in a RUG

(Resource Utilization Grouping) category if the physical therapist is in the

room with the aide while the services are being furnished.

APTA is also hearing from its members that, due to the implementation of the

PPS, SNF's are cutting back on their student programs. Again, APTA is aware

of no instance in which a denial was issued because a student was involved

with the provision of care. SNFs could be reducing their participation in

clinical education for any number of reasons. For example, SNFs are

reducing the number of physical therapy staff employed and, as a result, may

have fewer staff available to supervise students; due to changes in the

Medicare reimbursement methods, they may be attempting to maximize

productivity; or a SNF may be making a statement of opposition to the

proliferation of physical therapist education programs.

It is possible that HCFA may address the issues of students and aides in the

final rule on the SNF PPS, which is due to be published in May, 1999.

For listmembers, direct further inquiries to APTA via jerryconnolly@...

Re: student documentation

>The most recent newsletter from the Pennsylvania Physical Therapy

>Association states in print on page 26

>

> " Medicare will not pay for treatment to their beneficiaries by PT

>or PTA students. This decision is a strict interpretation of existing

>regulations. Physical Therapy must be provided by licensed individuals

>and the students are not. Students can watch and assist, but they cannot

>be the primary, direct caregiver for a Medicare patient. In this

>situation, they should function as aides. "

>

>Are others familiar with this? Where can I find this " interpretation " ?

>How are you handling this in your clinic?

>

>I personally can not imagine going through all of my clinical training and

>not working with the elderly. I learned so much from them! And I

>certainly would have been opposed to paying for my clinical education if I

>were going into a clinic to " function as aides " .

>

>Please advise. Thank you.

>

>Janet Moffitt Exley, PT, Director

>University of Pittsburgh at Titusville

>PTA Program

>

>

>------------------------------------------------------------------------

>

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