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  • The Post-Therapy Cap System: 5 Basics You Need to Know

    When Congress adopted a federal spending package that included the elimination of the hard cap on Medicare therapy services, it didn't just remove a rule—lawmakers also adopted a new system of payment thresholds and triggers, and a differential payment rate for physical therapist assistants (PTAs) and occupational therapy assistants (OTAs), among other things.

    APTA supported an end to the hard cap, which is a significant win for the most vulnerable Medicare patients, but other parts of the system that replaced it are problematic.

    The elimination of the hard cap is retroactive to January 1, 2018, but not all details of the post-cap system have been worked out, and it's possible that some may change before their implementation dates. In the meantime, here are the basic elements of the new system.  

    1. It boils down to a threshold for using KX modifiers and a trigger for possible medical review.
    The basic idea is this: outpatient therapy under Medicare now has a $2,010 threshold; services delivered beyond that require a KX modifier indicating that the service meets the criteria for a payment exception. When therapy reaches $3,000, it's subject to possible targeted medical review—although CMS didn't receive any additional funding to conduct these reviews.

    2. Physical therapy and speech-language pathology still are lumped together in the thresholds.
    Just as in the previous payment system that included a hard cap and exceptions process, the new system doesn't separate physical therapy from speech-language pathology in establishing thresholds. Those $2,010 and $3,000 limits are for physical therapy and speech-language pathology therapy combined—another element opposed by APTA.

    3. The thresholds apply to all part B outpatient therapy services—including services provided by hospital outpatient departments.
    For the brief time beginning in January when the therapy cap was in place, hospital outpatient facilities were not subject to the cap. That changed with the adoption of the budget package, and now these departments or clinics are subject to the thresholds: $2,010 for use of the KX modifier and $3,000 for potential targeted medical review.

    4. The PTA payment differential will start in 2022—along with a special claims designation.
    In the post-cap payment system, outpatient therapy services performed by physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) will be reimbursed at 85% of the Medicare physician fee schedule—a change opposed by APTA. However, that's not set to happen until 2022.

    For now, claims do not include a way to designate whether a service was delivered by a PTA, but that too will change by 2022, when CMS will develop a modifier to make that distinction. Between now and then, look for opportunities to comment on proposed rules around this process, along with guidance and more details as they develop.

    5. Home health also will be subject to the PTA payment differential, absent a plan of care.
    The 85% payment differential for services provided by a PTA or OTA will apply to home health care provided to Medicare part B beneficiaries—but only when a home health plan of care is not in effect. The budget deal that resulted in the end to the hard cap also established other new rules for home health. PT in Motion News recently reported on these additional changes.

    Comments

    • Important question regarding number 5 how is a PTA or an OTA providing care and being reimbursed by Medicare when there is no plan of care in a home health setting?

      Posted by Shaun Spade on 2/16/2018 4:40 PM

    • I am interested to know why the APTA is opposed to the 85% payment differential. I don't know any practicing therapists against it.

      Posted by J Cohen on 2/16/2018 8:33 PM

    • I was told that PTA's can't treat Medicare B clients without supervision. So they can't see clients when a POC is not in effect anyway.

      Posted by Bryan fean on 2/16/2018 9:04 PM

    • Concern, about our future,PTA maybe come less popular .I belive solution to even out cost for PTA,services will be group threrapy again .All this will effect pt's care.2022 it is coming soon.

      Posted by Katrina on 2/17/2018 12:41 AM

    • What is the APTA doing to help PTA’s from this and it will devastate thousands. This is a serious issues.

      Posted by Ryan leavitt on 2/17/2018 12:10 PM

    • For #5: From my knowledge if a medicare patient was to visit their physician, however only was seen by the physician assistant, doesn't medicare still reimburse that physicians practice the same amount? So as a PTA why should we NOT take offense to this change, I still provide the same quality of service. This will have detrimental effects on our industry if it is not changed, we need to wake up!

      Posted by Greg on 2/19/2018 9:44 AM

    • Is this the writing on the wall that the PTA /COTA profession is not longer needed or wanted? 85% payment differential, will companies be willing to hire PTA's & COTA's? Will the difference in our pay scale outweigh the 15% lost revenue?

      Posted by Catherine Norman -> CNQaEH on 2/19/2018 1:00 PM

    • I'm ok with all of these legislative changes. I've been treating patients over the cap when needed, discharging before the cap when appropriate. Regarding PT in Motion’s points in order: 1. Is a non starter, KX is not hard to apply and may allow for tracking of those guilty of defrauding Medicare. I'm ok knowing I'm being monitored because I treat only as medically necessary. 2. I own a PTPP, and wasn't affected by the PT, SPT cap. Now less than ever even with the repeal, even though I'm considering changing to a ORF. 3. Good, I never have been able to understand why hospitals received differential treatment with the cap or why they receive reimbursement for part B above private practices. 4. PTA's cost less than PT's. I pay PTA's 33% less than PT's, a cost differential is appropriate. I will likely modify current treatment practice by PT during examination days. 5. Home Health part B will be hard hit but does not effect me and may in fact benefit me from decreased episodes of care. I hope the days of HH providing community reintegration actually becomes the practice instead of just a Medicare standard. There is a reason why practice owners spend $10K+ a month for overhead and it isn't just on dumbbells and cuff wts. When did outpatient clinics loose they're capstone status for returning patient's to community level?

      Posted by Joseph P. Koloc on 2/19/2018 6:03 PM

    • I feel as though all PT's and PTA's should be in support to oppose the differential. Basically it is going to be a 15% reduction in revenue which will affect both PT/PTA's. I am a clinic owner and looking at the business overall revenue and expenditures are how raises, cont. educ, health care supplement, vacation, etc are determined. Clinic overhead does not usually decrease, it typically increases (front desk employees, payroll, billing expenses, supplies, liability ins, etc). This cut in revenue will eventually impact both PT and PTA salaries and/or force clinics to see more pts per hour to capture the loss in revenue. I don't know about you but I feel like we provide a valuable service no matter if the PT or PTA provided the actual treatment. I know in our clinic the PTs and PTA's are always in contact discussing the pts case and the PT is very involved. Why are we agreeing to devalue our service? Its bad enough we are not getting paid what we are worth already. Have you ever compared what a hair dresser, mechanic, nail technician, service repair tech, personal trainer, massage therapist or lawyer charges compared to what we charge and actually get paid? We are digging ourselves into a financial hole by not standing up for our knowledge, service and profession.

      Posted by Samantha Strickland -> =NU[@F on 2/20/2018 3:47 PM

    • J Cohen; I don't know what world you live in, but I have not personally talked to anyone who feels the 15% reduction is appropriate. As a clinic owner I will have to make up the 15% somewhere. And forget all those who are saying we will have to treat more patients per hour, are they going to do that and over bill medicare (more than 4 units per hour per therapist?

      Posted by John Sutherland on 2/21/2018 5:21 PM

    • I am not sure why any PT thinks this is a victory, or "great news". Here is what is boils down to: WE ARE GETTING LESS MONEY FOR PT SERVICES! Like every other insurance company continually cutting our reimbursement, now we get a cut from Medicare. In the 15 years I have been practicing, two things are true. First all expenses continue to increase(rent, payroll, etc). Second, reimbursements/visits continue to go down. Why does our association continue to accept these bills as a VICTORY? This is awful for our profession, and our association should be banning together to tell insurances and Medicare that we are not going to take it anymore. But not our association, just take the scraps and keep your mouth shut.

      Posted by Michael Green on 2/21/2018 5:33 PM

    • As a PTA and Regional Director, I can say I’m not happy about the reduction. However, we have been fighting for Cap repeal for nearly 20 yrs. and there has to be some sort of trade-off. At the NASL conference earlier this month the APTA, AOTA, and ASHA leaders addressed this by saying they were surprised by the reduction but the time frame also allows for time to fight it. They asked us to not give up on this fight. Has anyone seen if this reduction is from the total reimbursement or if it is from the work component of the code. That could make a huge difference in terms of how much is actually taken away. In regards to PTAs and COTAs not being needed, I think it would be financially irresponsible of ANY setting to adopt this practice. It would not make financial sense to pay a PT to perform treatments to avoid a 25% payment reduction. In nearly all settings a PT makes at least 25% more than a PTA. The 25% reduction would still leave a bigger profit than having a PT perform the treatments. Many settings already face much bigger payment reductions due to CPT code bundling by managed care companies when compared to the Medicare B reduction- yet PTAs are still preferred for the bulk of the treatment time. I think we all need to take a breath and realize a reduction is much, much better than a hard cap situation.

      Posted by Mark Stapleton on 2/21/2018 5:51 PM

    • I completely disagree with the PTA payment differential. The services a PTA codes to bill for are just as valuable to the patient as when those same codes are provided by a PT. If I felt the PTA that I work with was not providing the same level or quality of exercise instruction, manual therapy or administration of modalities, etc. as I provide then I would not want her to see my patients at all. The difference between a PT and a PTA (and why we are paid more) is because PTs perform evaluation, assessment, set the plan of care, and are ultimately responsible for the care performed by the PTA. That is why PTs are paid more and the greater reimbursement comes when billing evaluation codes. Treatment codes should be reimbursed the same no matter who performs them. If a PT thinks the quality of their treatment is so much better than that of their PTA then I would question why you would have that PTA working with you at all.

      Posted by Mindy Nagel on 2/21/2018 7:01 PM

    • PT and SLP being combined has NEVER been logical. Will it ever end? While congress was making changes WHY did they not separate them? The OP setting is the only setting in which the PT is required to be on premise for a PTA to even treat. Nurse Practicioners are allowed to treat without the MD being there. Imposing a 15% reduction in our setting again is a cut to the small business private practioner. Where congress needs to focus on making cuts is unnecessary surgeries, injections and MRIs - all outlandishly expensive. PT OP services is the cheapest option available and they continuing attack us WTHeck!

      Posted by Jerry Yarborugh on 2/21/2018 11:17 PM

    • I am shocked by the therapists who comment this is okay,and not against it. This will have a huge effect across the profession with some devastating consequences, that no therapist should be in favor. If we as a profession show the same apathy as we have for other issues, and offer no resistance,then we will be subject to other changes. What could be next? Different reimbursement for BSPT versus MSPT, versus DPT? How about less reimbursement for a PT treating an orthopedic patient with out an orthopedic specialty certification. This seems absurb,but when we have opened the door to changes without active resistance, then anticipate a dilution.

      Posted by kelly Jessop on 2/22/2018 5:19 AM

    • This is not a victory at all. The same issues have been going on for 40 years without resolution- the diminishment of the professional autonomy of the physical therapy community. It is not a win win it is a looser for all of the profession, PT and PTA.

      Posted by Deborah Wiegand Snyder on 2/22/2018 9:27 AM

    • Unless I am missing something, I am confused. I guess I do not see the recent ruling as a victory for the PT profession. I was under the impression that when the cap was repealed it would all be repealed. Now they are calling it a "threshold" and keep it combined with speech therapy. To have a threshold and the need for the KX modifier has really brought us nowhere in this current fight. It seems to me all it has done is to create new restrictions on our services and payment. We need to be fighting for a complete repeal...no "threshold", no KX, and for the same practice rights as other medical providers i.e. full direct access, no direct supervision for PTAs just like the PAs, NPs, etc. Enhance the medical and audit reviews to find fraud and abuse instead of arbitrary caps or thresholds. We are a doctoring profession but by no means on level playing ground.

      Posted by Casey Cortney on 2/22/2018 2:32 PM

    • When will the APTA start standing up for the PT's (and PTA's) and stop accepting the medicare table scraps? You wonder why the membership rate is abysmal? Because they do very little to advance the profession.

      Posted by Sick of the politics on 2/22/2018 3:44 PM

    • Isn't is about time that PT's are allowed to OPT out of Medicare and accept cash? MD/DO's can opt out why won't PT's opt out and let the populations vote in legislators that will benefit Medicare recipients. Tell APTA to let CMS know the body(APTA Membership) is tired of being diluted and wants to receive what they deserve. Grant PT's the option to play their own game rather than government puppets accepting scraps.

      Posted by SEH on 2/22/2018 4:49 PM

    • There are some very good points being made here: 1. PTA's should be reimbursed the same for treatment provided, as the treatment is (or should not be) inferior to that of the PT. 2. PT is by far the least expensive treatment option for most orthopedic conditions and we should be promoting that, not allowing our reimbursement for services to be continually cut. 3. A lot of PT treatments can be performed for the cost of just 1 injection, diagnostic exam or surgery. So continue to promote therapy as the best first option for keeping medical costs down. Not to cut the legs out from under us. 4. PTA's provide valuable service, esp. in rural areas where it is harder to recruit PT's to come work. 5. There isn't a difference in reimbursements for PA's vs. MD's, so why should we accept a difference. 6. Business costs all continue to rise and professionals deserve to be paid a good salary/benefits for the services provided. But the ongoing cuts continue to make that more difficult. 7. There does not need to be a difference in reimbursement between private practices & hospital PT services. That's ridiculous. 8. Also it makes no sense that a PTA has to be supervised on-site in an OP setting, whereas in the hospital, SNF or HH settings (which usually involve much more medically involved clients with more potential for complications) can practice w/o supervision. 9. Using some common sense and good business practices at the national level would go a long way towards helping our profession, instead of settling for what they want to give us, as if we are the little brother in the health care spectrum of care.

      Posted by Scott Carnahan on 2/22/2018 5:04 PM

    • I have been in full time solo private practice for 32 years. Sadly these ongoing issues expressed above, of increased expenses/overheard and decreased payment from ALL insurances point to a trend and frustrating direction that soon, I will need to join as well, that is to “just go private pay only”, reducing greatly access to my care by elders and families I have known for several decades, and making this profession too, that for the more privileged! ...how to keep balance, a sense of integrity and ethics of care, and service and healing in such a system? I feel sadness for the younger generation of PTs and PTAs and look with curiosity at what the future will be for our profession.

      Posted by Anne Hanks on 2/22/2018 7:04 PM

    • Not that I recommend thinking in terms of caps, I am opposed to anything that arbitrarily impacts my clinical decision making, but we live in a country where healthcare is still something we pay for. Therefore, it is still fair game to market pressures, supply and demand etc. Think of this cap repeal as a jump from $2,010 to $3,000 or $900 more right. moving forward (2022) a treatment is about $100 but less PTA cost savings of $15 per treatment over the entire episode of care, therefore a PTA makes $2,550 episode of care while the PT working alone could still earn the full $3,000. But, this is still a relative increase of $540 for the PTA over old cap and $990 for the PT right. From CMS perspective, this is still a win and here’s why. Our boomers are aging and more of them will be 97162's than 97161's for their examination codes. I feel like I've already seen this phenomenon in the last 2 years alone. I don't mean to give too much credit to our political representation here or be overly morbid, but is it possible someone with foresight realized the boomers are entering the last phase of their life-cycles, the expensive one. It makes sense to lift the cap. This allows improved health and decreased cost during this part of the boomers life cycle by more access to us, the improved health and decreased cost specialist. There has to be a balance on the ledgers though, hence the PTA cut. Think of our profession going through the same changes that primary care is going through. There are ton’s more care extenders in the PCP's offices and hospitals including PA's and ARNP’s who are doing a lot of the care under the MD's supervision and doing a great job! They aren’t getting the salaries cut and neither will PTA’s. There will be more work and more money, not less. We simply need to continue working on how to provide better care for less cost overall.. For those who aren’t willing to see negotiation as necessary and hope to always have a win, win, that’s just not how economics (or life) works. However, if one simply reads one 60 page insurance contract required by private practice owners, one realizes very quickly who has the power and who is REALLY wining. Those in power are those who hold the purse strings. Insurance companies are the power brokers in every aspect of our health care system and by most accounts are the big reasons for our countries healthcare troubles. If anyone is to blame for decreased reimbursement to providers and increased costs in healthcare it is not Medicare, it is the insurance companies receiving Medicare assignment. Every year insurance companies siphon off the lions share of reimbursement while creating more barriers to reimbursement, unreasonable authorization requirements and limiting participation to Medicare part C funded programs. I can still examine a Medicare patient, send my examination to the patient’s PCP, have it signed the same day and see the patient the next day in my office and get paid. My hope is that while all these legislative changes are taking place, some savvy politician, at the urging of our APTA, will require changes take place in the insurance companies. After all, they receive our tax dollars to care for members in our communities and therefore our patients and we know how to care for them better than any insurance company. I believe the APTA should push for compelling transparency by insurance companies with regards to the management of CMS funded Medicare Part C and decrease over burdensome barriers to fast and effective care.

      Posted by Joseph P. Koloc on 2/22/2018 8:41 PM

    • Nice job APTA 1. We still split our money with the SLPs. 2. Re-imbursement is going down overall 3. Targeted medical review now happens earlier 4. Benefit expanded by approx $50 (since we're still splitting the benefit with SLP) Your sad attempt to market this as a victory and the misinformation that has already spread among the public has convinced me not to renew my membership. This "victory" clearly only has any potential benefit to private practice owners who are not a majority of PTs but somehow drive a majority of of the APTA

      Posted by Bernard Marchisio on 2/22/2018 10:53 PM

    • It seems like no matter what we do, the health insurance companies continue to get away with anything they want. The reimbursement rates are already pitiful for OP private practices, and now they want to force some PTA's out the door. Here in Ca, as a PTA, we spend more time with patients than the PT's do because of the lack of using Aides. Congress isn't thinking about the patients welfare, just their bottom line.

      Posted by tony cossey on 2/23/2018 1:07 AM

    • This is the most nonsensical and illogical rule that I have ever had to put up with. The same decisions are been shoved at us every time and losing grounds every time we accept it as a group but yet still we are expected to provide more quality. How on earth is this possible. it is tantamount to saying, your service to our insured are less desired and valuable that you should be happy that we are paying you the little that we are and hey, close your practice if you don't like it. I know I am not running a profitable business and I cannot grow under these conditions of reimbursements and restrictions. How can you demand the kind of restrictions upon us for supervision of PTAs, 1 on 1 care, and limit caps and bunched us with SLP and expect that we be profitable. Try this such regulations with any other business and see how long your service lasts. We as a professional group must start to demand payment upfront and fee for service as we continue on the track of evidenced based quality care delivery models. Until then, we as a profession will someday be impossible to exist. Hope we start to stand up on our own and hold our grounds before we face the reality of extinction.

      Posted by Ibrahima Diallo on 2/23/2018 10:17 AM

    • In the future we will be paying the patients and their insurance companies to let us provide them with our services, and we’ll have to sell drugs out of the back of the clinic to afford to keep the lights on. You really can’t make this stuff up anymore. So what are we supposed to do? Charge people cash for our best quality care and exclude all but the very financially well off? Book 4-5 patients an hour and hand them a list of exercises so we can write our 40 notes a day while they mindlessly ride the NuStep just to afford to pay our employees a fair salary? I’m sure I’m not the only one here that knows A LOT of good PTs leaving the field to go into real estate or weaving baskets or something. And I gotta say I can’t blame them anymore. Can you? APTA- what do you want me to tell my students when they ask me what the future holds for our profession? What should I tell them when they ask me if it’s worth their mountains of student loan debts? Because I’m at a loss for positive responses to those questions these days... Maybe it’s time that we as a profession make an effort to prove our worth. Maybe it’s time that we demand to be paid what our services are worth. Maybe it’s time that we quit in-fighting amongst ourselves over petty crap that doesn’t matter and stand up to the insurance companies, the AMA, and all of the other organizations that would love to feed us table scraps and act as if our services have no value. Otherwise there’s gonna be a lot less of us having this discussion every year and every clinic will be nothing but new grads in a decade.

      Posted by Nate on 2/25/2018 2:06 AM

    • If the cap was eliminated, then why is there still a "cap" of $2010?

      Posted by William on 2/26/2018 3:56 PM

    • Curious, are Physician's Assistants reimbursed at a lower rate? If so, we don;t have an argument. If not, it's because the AMA has more power ind influence. We need more members, this is not the time to quit even though this is a disappointing for most.

      Posted by Stephen Kolenda -> =HQ\CL on 2/27/2018 10:43 AM

    • PA's also have a 85% reimbursement rate compared to a physician. I am a PTA and I believe my unit of manual therapy or ther ex, ect.. has the same effectiveness as a PT, however if a PA is not reimbursed at the same, then I don't think an argument is to be won for a PTA. HOWEVER, PA's are allowed to implement a "incident to" code that allows the PA's tx to be billed at 100%. We should be fighting for the same provisions that PA's have. If you look below you will see the requirements for PA 100% billing, which I think most clinics practice... Office-based services Services provided by PAs in private offices and clinics may be billed under the PA’s NPI or Medicare’s “incident to” provision if strict billing guidelines are met. The “incident to” provision allows PA-provided services to be billed under a physician name. Payment is made at 100 percent of the fee schedule if: 1. The physician personally treats, establishes the diagnosis, and develops the plan of care for a Medicare patient on the first visit for a particular medical problem. 2. A physician in the group (need not be the same physician who originally treated the patient) is physically on site when the PA provides follow-up care on a future visit. 3. The physician personally treats and diagnoses established Medicare patients who present with new medical problems. 4. The physician has an active part in the ongoing care of the patient. Subsequent services by the physician must be of a frequency that reflects his/her continuing active participation in, and management of, the course of the treatment

      Posted by Craig Vandermaden on 2/28/2018 10:12 AM

    • Why is Medicare still saying that the CAP is $2010.00

      Posted by Cara Giusti -> >JTb>L on 3/1/2018 11:44 AM

    • I agree with you Tony and Nate. Our profession has continued to be marginalized by dropping insurance company reimbursement. I continue to be less concerned regarding the PTA differential, but supremely concerned about contracts offered by Medicaid and Medicare and Workers Compensation companies. It’s become commonplace to offer reimbursement at 50-60% of state and federal fee schedules. Where does that money go? If you have a private practice and pay your clinician's market value, you have to earn at least 2-3 times more than they cost. If you don't, you won't be profitable and be out of business pretty quick. Somewhere along the line, practice owners, began accepting this decline in our reimbursement and insurance companies exploited this opportunity, just as any business would. This needs to change. I believe the APTA and our state associations should lead the conversation regarding increased reimbursement by insurance companies as they have the organizational structure to unite practices to apply upward pressure on reimbursement. This could be done on a segment by segment basis, and I recommend we start with workers compensation nationwide, not just statewide. It's time for practice owners to return to an environment where they no longer have to contract with middlemen who are killing reimbursement in work comp. Employers are paying premiums, workers compensation insurance companies receive the premiums and then farm out our profession to the middlemen who then get us over the barrel head. Lets cut out all the non nonsensical, in between bureaucratic nonsense and offer great service for better prices ourselves. When was the last time the APTA actually was involved in a conversation about reimbursement at the individual practice level? Is this beyond they’re scope or is this not what would lead to change at the top of the decision making hierarchy?

      Posted by Joe on 3/6/2018 8:00 PM

    • I think it’s time for the APTA to be honest with PTA programs & the PTA programs need to be honest with the next generation of prospective PTA’s. PTA jobs are declining. It is a fact. I have been told by numerous PT’s that they no longer hire PTA’s or when one quits, they purposely replace them with a PT. I have heard PT’s tell observation students NOT to go to PTA school. The “better together” campaign needs some serious reflection before one more prospective PTA student spends a dime on an evaporating degree / career. Read this blog post from 2015....PTA’s need to read the writing on the wall. http://www.evidenceinmotion.com/blog/2015/04/16/here-we-go-againthe-ptahow-do-we-save-us-from-ourselves/

      Posted by Roger on 3/31/2018 7:17 PM

    • The margins are so thin in healthcare, especially in SNFs/LTC's, even non-profits use their therapy departments to help make up for lost revenues and that amount is going to be affected by the changed PTA reimbursement. This could be extremely detrimental to many facilities, especially the more rural areas. The change in reimbursement is truly unfair. As some above have mentioned are they going to bill less if a patient is seen by a PA or NP vs a physician? For 22 years since I graduated from my PTA program I have never seen the APTA support PTAs, in fact the contrary is true. I believe they wanted this and pushed for it on the Hill to undermine the PTAs in an attempt to elevate the PT. They pushed for the DPT programs for direct access like Chiropractors ... how's that working out for everyone? Do you have direct access yet? The APTA charges PTA's almost the same amount as PT's to be members but give them no voting rights or any real voice. This is why I will not support the APTA, they have ulterior motives. Their arrogance will be their undoing. Anyone with actual business sense understands the cost value of PTA's, at every level from small private practices to large health care organizations. I have NEVER met a patient who said to me they want to see the PT instead of me. I have seen bad PTA's and bad PT's for that matter - so that's not a valid reason. Looking at the PTA education as a means of keep reimbursement rates higher and decreasing the HUGE flood of programs I would suggest changing the PTA degree to a BS degree. Why the APTA isn't researching this and pushing for it is another example of the divide. As a profession, therapists and assistants need to be fighting together and I do not see that from the APTA.

      Posted by DJ on 4/12/2018 10:00 AM

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