Question: Under the SNF final rule how is the following situation handled?
A therapist is supervising a student (not in line of site) while the therapist is seeing another patient. How are the Part A SNF minutes applied? Do both the therapist’s patients and student’s patients minutes count as 1:1 or because the student is an extension of the therapist, are the minutes counted as concurrent. I’ve read the final rule document and am still confused.
What if we have the same scenario above except that the therapists and students patients are both Part B patients, how are CPT/charges handled?
Answer:The rules for allocation of student minutes remain exactly the same as you are currently working with, only the supervision requirement has changed. Therefore if the student treats a patient whether in line of site of the therapist or not those minutes are counted as if the therapist themselves were treating the patient. So, let’s review different situations:
1) The therapist treats a patient and the student is observing – Individual
2) The student treats the patient, the therapist is NOT treating or supervising anyone else – Individual
3) The therapist treats a patient and the student treats a patient – Concurrent
4) The student treats 2 patients and the therapist is NOT treating or supervisinganyone else – Concurrent
5) TWO students each treat a patient and the therapist is NOT treating or supervising anyone else – Concurrent
6) The therapist treats 2 patients and the student is observing – Concurrent
Now under Part B there is only one option for the therapist and that is personal supervision of the student, i.e. the therapist is directly with the student and patient, directing and taking personal responsibility for the patient care, then this time is billed as if the therapist themselves were providing treatment. As soon as the therapist starts to do anything else, then the time stops. The time is allocated to the appropriate CPT code not to group as the student is not considered the provider.
I hope this helps to eliminate the confusion.
