The Centers for Medicare and Medicaid Services (CMS) hosted a Medicare Learning Network call on November 15, 2018, entitled Inpatient Rehabilitation Facility (IRF) Payment and Coverage Policies: FY 2019 Final Rule. During the question and answer portion of the call, a listener asked whether or not the minutes provided by a therapy student, under appropriate supervision, count toward the “3-hour rule” (the therapy intensity requirement in the IRF setting). The CMS official responded that minutes provided by a student would not count, regardless of supervision. CMS did not offer any additional details on student supervision requirements that would allow students to effectively participate in education and training opportunities.
UPDATE: On December 11, 2018, representatives from AOTA, APTA and ASHA discussed the issue of training for therapy students in the IRF and Acute Hospital settings with CMS. Subsequent to these discussions, CMS sent a letter to each of the associations stressing they have not changed any policy regarding Conditions of Participation and the provision of healthcare services by students in hospitals — this includes therapy students providing rehabilitative services in hospitals and IRFs. CMS also added that training in these settings is essential for the therapy students as well as all those involved in treating patients. They did note that they expect proper supervision of students by a licensed therapist for services to be counted toward the program requirements. To read the letter from CMS, click here.