How to bill for PTA services
By Marty Kotlar, DC, CHCC, CBCS

I run a very busy DC-PT practice and want to hire a physical-therapy assistant (PTA) to help the physical therapist (PT) see more patients. Are there any treatment guidelines I should know about? Also, the PT has asked for guidance on creating patient-treatment plans. Do you have any treatment plan recommendations?

A PTA is someone who is licensed as a PTA, if applicable, by the state in which he or she practices, and:

• Has graduated from a two-year college-level program approved by the American Physical Therapy Association; or

• Has two years of appropriate experience as a PTA and has achieved a satisfactory grade on a proficiency examination conducted, approved, or sponsored by the U.S. Public Health Service, except that these determinations of proficiency do not apply with respect to persons initially licensed by a state or seeking initial qualification as a PTA after Dec. 31, 1977.

The services of PTAs are included as part of most insurance coverage benefits and billed by the supervising PT. PTAs may not provide evaluation services, make clinical judgments or decisions, or take responsibility for the service. They act under the direction and supervision of the treating PT and in accordance with state laws.

A PT must supervise PTAs. Supervision levels for outpatient rehabilitation therapy services include:

• Personal supervision (in the room);
• Direct supervision (in the office suite); and
• General supervision (physician or nonphysician practitioner — NPP — is available, but not necessarily on the premises).

The level and frequency of supervision differs by setting, as well as by state or local law. PTAs in private practice require direct supervision unless state practice requirements are more stringent, in which case, state or local requirements must be followed.

The services of a PTA are not to be billed as services “incident to” a physician’s/NPP’s service because they do not meet the qualifications of a therapist. Medicare does not recognize PTAs as providers; therefore, they are not allowed to receive a Medicare provider number. Their services can only be billed by the supervising PT.

A written treatment plan must be established before treatment begins. The plan is established when it is developed (that is written or dictated). The signature and professional identity of the person who established the plan and date it was established must be recorded with the plan.

Establishing the plan is not the same as certifying the plan.

Evaluation and treatment may occur and are billable on the same day or at subsequent visits. It is appropriate for treatment to begin when a plan is established.

Treatment may begin before the plan is committed to writing only if the treatment is performed or supervised by the same clinician who establishes the plan. Payment for services provided before a plan is established may be denied.

The plan of care shall contain, at minimum, the following information:

• The diagnoses;
• Long-term treatment goals; and
• Type, amount, duration, and frequency of therapy services.

Marty Kotlar, DC, CHCC, CBCS, is the president of Target Coding. Target Coding, in conjunction with Foot Levelers, offers continuing-education seminars on CPT coding and compliant documentation. He can be reached at 800-270-7044, by e-mail at drkotlar@targetcoding.com, or through his Web site, www.targetcoding.com.