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Regulatory &
Compliance

Therapy Associations Release Joint Statement on Use of Students in Hospitals/Inpatient Rehab Facilities

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.

Unlike in the SNF and OP settings, where student supervision and use of minutes are clarified in Chapter 3, Section O of the RAI Manual and the Medicare Benefit Policy Manual Chapter 15, Section 230, there is no similar documentation from CMS outlining student services in the IRF setting.

On Friday, November, 16, 2018, APTA, AOTA and ASHA released a joint statement announcing their request for a meeting with CMS and their belief that this issue needs to be addressed and clarified to allow for the continued development of effective, well-trained clinicians.

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