9-28-10
CMS Manual Addresses Student Supervision in SNFs
CMS has updated the Resident Assessment Instrument (RAI) Manual for Minimum Data Set Version 3.0 (MDS 3.0), which went into effect October 1, 2010. All certified Medicare or Medicaid nursing facilities must complete, record, encode and transmit the MDS for all residents in the facility, regardless of age, diagnosis, length of stay or payment category. The RAI Manual provides guidance for using the MDS. CMS’ changes include revisions to Chapter 3, Section O of the RAI 3.0 Manual (pages 19-21) regarding therapy students. The revisions describe how students would be involved in individual therapy, concurrent therapy and group therapy in SNFs.
Policy Regarding Students – SNF Part A & B – MDS 3.0 RAI Manual (Effective October 1, 2010)
O0400: Therapies (cont.)
Therapy Students
• Medicare Part A—Therapy students must be in line-of-sight supervision of the professional therapist (Federal Register, July 30, 1999). Time may be coded on the MDS when the therapist provides skilled services and direction to a student who is participating in the service under line-of-sight supervision.
• Medicare Part B—The following criteria must be met in order for services provided by a student to be billed by the long-term care facility:
—The qualified professional is present and in the room for the entire session. The student participates in the delivery of services when the qualified practitioner is directing the service, making the skilled judgment, and is responsible for the assessment and treatment.
—The practitioner is not engaged in treating another patient or doing other tasks at the same time.
—The qualified professional is the person responsible for the services and, as such, signs all documentation. (A student may, of course, also sign but it is not necessary because the Part B payment is for the clinician’s service, not for the student’s services.)
—Physical therapy assistants and occupational therapy assistants are not precluded from serving as clinical instructors for therapy assistant students while providing services within their scope of work and performed under the direction and supervision of a qualified physical or occupational therapist.
Modes of Therapy
A resident may receive therapy via different modes during the same day or even treatment session. The therapist and assistant must determine which mode(s) of therapy and the amount of time the resident receives for each mode and code the MDS appropriately. For any therapy that does not meet one of the therapy mode definitions below, those minutes may not be counted on the MDS. The therapy mode definitions must always be followed and apply regardless of when the therapy is provided in relationship to all assessment windows (i.e., applies whether or not the resident is in a look back period for an MDS assessment).
Individual Therapy
The treatment of one resident at a time. The resident is receiving the therapist’s or the assistant’s full attention. Treatment of a resident individually at intermittent times during the day is individual treatment, and the minutes of individual treatment are added for the daily count. For example, the speech-language pathologist treats the resident individually during breakfast for 8 minutes and again at lunch for 13 minutes. The total of individual time for this day would be 21 minutes.
When a therapy student is involved with the treatment of a resident, the minutes may be coded as individual therapy when only one resident is being treated by the therapy student and supervising therapist/assistant (Medicare A and Medicare B). The supervising therapist/assistant shall not be engaged in any other activity or treatment when the resident is receiving therapy under Medicare B. However, for those residents whose stay is covered under Medicare A, the supervising therapist/assistant shall not be treating or supervising other individuals and he/she is able to immediately intervene/assist the student as needed and the student and resident are both under line-of-sight supervision.
Concurrent Therapy
Medicare Part A
The treatment of 2 residents, who are not performing the same or similar activities, at the same time, regardless of payer source, both of whom must be in line-of-sight of the treating therapist or assistant.
When a therapy student is involved with the 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 and the therapy student and the resident the student is treating are in line-of-sight of the supervising therapist/assistant; or
· The therapy student is treating 2 residents, both of whom are in line-of-sight of the therapy student and the supervising therapist/assistant, and the therapist is not treating any residents and not supervising other individuals; 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, both of whom are in line-of-sight.
Medicare Part B
The treatment of two or more residents who may or may not be performing the same or similar activity, regardless of payer source, at the same time is documented as group treatment.
Group Therapy
Medicare Part A
The treatment of 2 to 4 residents, regardless of payer source, who are performing similar activities, and are supervised by a therapist or assistant who is not supervising any other individuals.
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 all the residents participating in the group (see definition above) and the therapy student are in line-of-sight of the supervising therapist/assistant who is not treating any residents and is not supervising other individuals (students or residents); or
· The supervising therapist/assistant is providing the group treatment and the therapy student is not providing treatment to any resident.
Medicare Part B
The treatment of 2 or more individuals simultaneously, regardless of payer source, who may or may not be performing the same activity.
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 group treatment and the supervising therapist/assistant is present and in the room and is not engaged in any other activity or treatment; or
· The supervising therapist/assistant is providing group treatment and the therapy student is not providing treatment to any resident.
