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December 20, 2018 Update
Today, APTA, APTA and ASHA received clarification the Centers for Medicare and Medicaid Services (CMS) regarding the use of students in inpatient rehabilitation facilities (IRFs).
Highlights of the letter:
- CMS believes that clinical training in hospitals is essential for educating future therapists and other health care professionals.
- CMS has not changed its policy regarding the Medicare Hospital Conditions of Participation and the provision of services by students in hospitals, including therapy students providing rehabilitative services in hospitals and IRFs.
- There is no Medicare Hospital Condition of Participation, specifically 42 CFR 482.56, or interpretive guidance that prohibits therapy students from providing therapy services as part of their training program.
- CMS notes that per 42 CFR 482.56, the director of a hospital's rehabilitation services must have the necessary knowledge and expertise to supervise and administer the services, and must ensure the services are organized and staffed to ensure the health and safety of patients. The director's responsibilities extend to all therapy students providing services in the hospital as part of their training program.
- Therapy student services furnished under the supervision of a qualified therapist or therapy assistant may count toward the intensive rehabilitation therapy program requirement.
- The Medicare Conditions of Participation require hospitals to comply with all federal, state, and local laws related to the health and safety of patients, ensure medical staff is accountable to the governing body for the quality of care provided to patients, and have an organized medical staff responsible for the quality of care provided to patients by the hospital. Students that provide services and care to patients in the hospital as part of the training program, their supervisory faculty, and any hospital staff acting as student preceptors are subject to these levels of oversight as well as any standards and requirements established by their training programs and by any national organizations, such as American Physical Therapy Association, American Occupational Therapy Association, and American Speech-Language-Hearing Association.
Prompted by member inquiries that began in the spring of 2018, the three therapy groups requested this clarification from CMS. Shortly after the groups submitted this request, CMS hosted a Medicare Learning Network event entitled Inpatient Rehab Facilities (IRF) Payment and Coverage Policies: FY 2019 Final Rule on Thursday, November 15. During this event, a number of questions were posed to CMS officials about whether student services can count towards the three-hour rule/intensity of therapy services requirement in the IRF setting. CMS clarified that students are not qualified providers of skilled rehabilitation services; however, CMS did not offer additional details on student supervision requirements that allow students to participate in clinical education and training.
On December 11, 2018, APTA, AOTA and ASHA met with CMS to discuss the issue in more detail. During this collegial meeting, CMS affirmed its support for clinical education and concluded the meeting by agreeing to provide written clarification on this topic in the near future.
Subsequently, CMS removed from its website the audio recording and transcript associated with the IRF Payment and Coverage Policies: FY 2019 Final Rule call held on November 15.
On December 20, 2018, CMS provided to the three therapy organizations, APTA, AOTA, and ASHA a letter clarifying the agency's views related to therapy students in hospitals (.pdf).
Please feel free to share this update and CMS's letter with your colleagues, peers, clinical educators, and students.