News Alert: CMS: Clarifies Counting of Student Therapy Minutes

IRFs can breathe easier; no change in policy.

CMS has clarified the question of counting minutes of therapy provided by students.

The Inpatient Rehabilitation Facility (IRF) world reacted in shock to an unexpected statement made during a November Medicare Learning Network call wherein a Centers for Medicare & Medicaid Services (CMS) staffer responded to a listener’s question related to counting minutes of therapy provided by a therapy student with guidance that these minutes would not count, regardless of the level of supervision.  

Following that call, the therapy professional associations –the American Physical Therapy Association (APTA), American Occupational Therapy Association (AOTA), and the American Speech and Hearing Association (ASHA) –- requested a meeting with CMS to address their concerns.

During the meeting on Dec. 11, CMS representatives indicated that there had been no change in policy related to the provision of therapy services – and, more importantly, related to student participation – during 2018. In a follow-up letter to the associations earlier this week, CMS clarified that its current policy does not prohibit 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.

As IRFs breathe easier about this issue, it’s important to remember the following:

  • As we stated in our earlier article, Medicare Learning Network programs are designed to provide information, and not to set policy. There have consistently been CMS clarifications following training programs in response to questions from the field and responses to those questions.
  • IRFs should have clear policies on the involvement of students in patient care, along with clear descriptions of the supervision requirements.

Program Note:

 Angela Phillips will report this story on Monitor Monday, Jan. 14, 10 a.m. ET.

Facebook
Twitter
LinkedIn

Angela Phillips, PT

Angela M. Phillips, PT, is President & Chief Executive Officer of Images & Associates. A graduate of the University of Pennsylvania, School of Allied Health Professions, she has almost 45 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting Inpatient Rehabilitation Facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

Related Stories

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

2026 ICD-10-CM/PCS Coding Clinic Update Webcast Series

Uncover essential coding insights with nationally recognized coding authority Kay Piper, RHIA, CDIP, CCS. Through ICD10monitor’s interactive, on‑demand webcast series, Kay walks you through the AHA’s 2026 ICD‑10‑CM/PCS Quarterly Coding Clinics, translating each update into practical, easy‑to‑apply guidance designed to sharpen precision, ensure compliance, and strengthen day‑to‑day decision‑making. Available shortly after each official release.

April 13, 2026

2026 ICD-10-CM/PCS Coding Clinic Update: Fourth Quarter

Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s fourth quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.

December 14, 2026

2026 ICD-10-CM/PCS Coding Clinic Update: Third Quarter

Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s third quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.

October 12, 2026

2026 ICD-10-CM/PCS Coding Clinic Update: Second Quarter

Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s second quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.

July 13, 2026

Trending News

Featured Webcasts

Compliance for the Inpatient Psychiatric Facility (IPF-PPS): Minimizing Federal Audit Findings by Strengthening Best Practices

Federal auditors are intensifying their focus on inpatient psychiatric facilities, using advanced data analytics to spotlight outliers and pursue high‑dollar repayments. In this high‑impact webcast, Michael Calahan, PA, MBA, Compliance Officer and V.P., Hospital & Physician Compliance, breaks down what regulators are really targeting in IPF-PPS admissions, documentation, treatment and discharge planning. Attendees will learn practical steps to tighten processes, avoid common audit triggers and protect reimbursement and reduce the risk of multimillion-dollar repayment demands.

April 9, 2026

Mastering MDM for Accurate Professional Fee Coding

In this timely session, Stacey Shillito, CDIP, CPMA, CCS, CCS-P, CPEDC, COPC, breaks down the complexities of Medical Decision Making (MDM) documentation so providers can confidently capture the true complexity of their care. Attendees will learn practical, efficient strategies to ensure documentation aligns with current E/M guidelines, supports accurate coding, and reduces audit risk, all without adding to charting time.

March 31, 2026

The PEPPER Returns – Risk and Opportunity at Your Fingertips

Join Ronald Hirsch, MD, FACP, CHCQM for The PEPPER Returns – Risk and Opportunity at Your Fingertips, a practical webcast that demystifies the PEPPER and shows you how to turn complex claims data into actionable insights. Dr. Hirsch will explain how to interpret key measures, identify compliance risks, uncover missed revenue opportunities, and understand new updates in the PEPPER, all to help your organization stay ahead of audits and use this powerful data proactively.

March 19, 2026

Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue

Stay ahead of the 2026-2027 audit surge with “Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue,” a high-impact webcast led by Michael Calahan, PA, MBA. This concise session gives hospitals and physicians clear insight into the most likely federal audit targets, such as E/M services, split/shared and critical care, observation and admissions, device credits, and Two-Midnight Rule changes, and shows how to tighten documentation, coding, and internal processes to reduce denials, recoupments, and penalties. Attendees walk away with practical best practices to protect revenue, strengthen compliance, and better prepare their teams for inevitable audits.

January 29, 2026

Trending News

Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →

BLOOM INTO SAVINGS! Get 25% OFF during our spring sale through March 27. Use code SPRING26 at checkout to claim this offer.

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24