During the November Centers for Medicare and Medicaid Services (CMS) National Provider call with inpatient rehabilitation facilities (IRFs), CMS responded to a question related to the counting of minutes of therapy provided by a therapy student that these minutes would not count, regardless of the level of supervision.

This triggered much confusion and led to the therapy professional associations requesting a meeting with CMS to discuss and address this and their concerns surrounding this response. After this collaborative effort between these associations and CMS, CMS issued a clarification of its position on therapy students in IRFs.

CMS has noted that student therapists may participate in therapy provided in an IRF if the student is appropriately supervised, and that the time spent with the student may count towards satisfying intensity of therapy requirements for IRFs. Cited directly from the clarification:

“Regarding the IRF intensive rehabilitation therapy program requirement in 42 CFR 412.622(a)(3)(ii), CMS’s current policy does not prohibit the therapy services furnished by a therapy student under the appropriate supervision of a qualified therapist or therapy assistant from counting toward the intensive rehabilitation therapy program. However, IRFs provide a very intensive hospital level of rehabilitation therapy to some of the most vulnerable patients. To ensure the health and safety of this vulnerable population, CMS expects that all student therapy services will be provided by students under the supervision of a licensed therapist allowed by the hospital to provide such services.”

Contact Melissa Dehoff, RCPA Rehabilitation Services Director, with questions.