My thinking is that the answer is no. My understanding is that only a licensed PT can perform these services to be reimbursed by Medicare. Since an MD cannot be reimbursed, I believe that a D.O. would not be..but interested to hear from others.
230.1 - Practice of Physical Therapy(Rev. 179, Issued: 01-14-14, Effective: 01-07-14, Implementation: 01-07-14)A. GeneralPhysical therapy services are those services provided within the scope of practice ofphysical therapists and necessary for the diagnosis and treatment of impairments,functional limitations, disabilities or changes in physical function and health status. (See Pub. 100-03, the Medicare National Coverage Determinations Manual, for specificconditions or services.) For descriptions of aquatic therapy in a community center poolsee section 220C of this chapter.B. Qualified Physical Therapist DefinedReference: 42CFR484.4The new personnel qualifications for physical therapists were discussed in the 2008Physician Fee Schedule. See the Federal Register of November 27, 2007, for the fulltext. See also the correction notice for this rule, published in the Federal Register onJanuary 15, 2008.The regulation provides that a qualified physical therapist (PT) is a person who islicensed, if applicable, as a PT by the state in which he or she is practicing unlesslicensure does not apply, has graduated from an accredited PT education program andpassed a national examination approved by the state in which PT services are provided.The phrase, “by the state in which practicing” includes any authorization to practiceprovided by the same state in which the service is provided, including temporarylicensure, regardless of the location of the entity billing the services. The curriculumaccreditation is provided by the Commission on Accreditation in Physical TherapyEducation (CAPTE) or, for those who graduated before CAPTE, curriculum approvalwas provided by the American Physical Therapy Association (APTA). Forinternationally educated PTs, curricula are approved by a credentials evaluationorganization either approved by the APTA or identified in 8 CFR 212.15(e) as it relatesto PTs. For example, in 2007, 8 CFR 212.15(e) approved the credentials evaluationprovided by the Federation of State Boards of Physical Therapy (FSBPT) and the ForeignCredentialing Commission on Physical Therapy (FCCPT). The requirements aboveapply to all PTs effective January 1, 2010, if they have not met any of the followingrequirements prior to January 1, 2010.Physical therapists whose current license was obtained on or prior to December 31, 2009,qualify to provide PT services to Medicare beneficiaries if they:• graduated from a CAPTE approved program in PT on or before December 31,2009 (examination is not required); or,• graduated on or before December 31, 2009, from a PT program outside the U.S.that is determined to be substantially equivalent to a U.S. program by acredentials evaluating organization approved by either the APTA or identified in8 CFR 212.15(e) and also passed an examination for PTs approved by the state inwhich practicing.Or, PTs whose current license was obtained before January 1, 2008, may meet therequirements in place on that date (i.e., graduation from a curriculum approved byeither the APTA, the Committee on Allied Health Education and Accreditation ofthe American Medical Association, or both).Or, PTs meet the requirements who are currently licensed and were licensed or qualified as a PT on or before December 31, 1977, and had 2 years appropriate experience as a PT, and passed a proficiency examination conducted, approved, or sponsored by the U.S. Public Health Service.Or, PTs meet the requirements if they are currently licensed and before January 1,1966, they were:• admitted to membership by the APTA; or• admitted to registration by the American Registry of Physical Therapists;or• graduated from a 4-year PT curriculum approved by a State Department ofEducation; or• licensed or registered and prior to January 1, 1970, they had 15 years offull-time experience in PT under the order and direction of attending andreferring doctors of medicine or osteopathy.Or, PTs meet requirements if they are currently licensed and they were trainedoutside the U.S. before January 1, 2008, and after 1928 graduated from a PTcurriculum approved in the country in which the curriculum was located, if thatcountry had an organization that was a member of the World Confederation forPhysical Therapy, and that PT qualified as a member of the organization.For outpatient PT services that are provided incident to the services of physicians/NPPs,the requirement for PT licensure does not apply; all other personnel qualifications doapply. The qualified personnel providing PT services incident to the services of aphysician/NPP must be trained in an accredited PT curriculum. For example, a personwho, on or before December 31, 2009, graduated from a PT curriculum accredited byCAPTE, but who has not passed the national examination or obtained a license, couldprovide Medicare outpatient PT therapy services incident to the services of aphysician/NPP if the physician assumes responsibility for the services according to theincident to policies. On or after January 1, 2010, although licensure does not apply, botheducation and examination requirements that are effective January 1, 2010, apply toqualified personnel who provide PT services incident to the services of a physician/NPP.C. Services of Physical Therapy Support PersonnelReference: 42CFR 484.4Personnel Qualifications. The new personnel qualifications for physical therapistassistants (PTA) were discussed in the 2008 Physician Fee Schedule. See the Federal Register of November 27, 2007, for the full text. See also the correction notice for thisrule, published in the Federal Register on January 15, 2008.The regulation provides that a qualified PTA is a person who is licensed as a PTA unlesslicensure does not apply, is registered or certified, if applicable, as a PTA by the state inwhich practicing, and graduated from an approved curriculum for PTAs, and passed anational examination for PTAs. The phrase, “by the state in which practicing” includesany authorization to practice provided by the same state in which the service is provided,including temporary licensure, regardless of the location or the entity billing for theservices. Approval for the curriculum is provided by CAPTE or, if internationally ormilitary trained PTAs apply, approval will be through a credentialing body for thecurriculum for PTAs identified by either the American Physical Therapy Association oridentified in 8 CFR 212.15(e). A national examination for PTAs is, for example the onefurnished by the Federation of State Boards of Physical Therapy. These requirementsabove apply to all PTAs effective January 1, 2010, if they have not met any of thefollowing requirements prior to January 1, 2010.Those PTAs also qualify who, on or before December 31, 2009, are licensed, registeredor certified as a PTA and met one of the two following requirements:1. Is licensed or otherwise regulated in the state in which practicing; or2. In states that have no licensure or other regulations, or where licensure doesnot apply, PTAs have:o graduated on or before December 31, 2009, from a 2-year college-levelprogram approved by the APTA or CAPTE; ando effective January 1, 2010, those PTAs must have both graduated from aCAPTE approved curriculum and passed a national examination for PTAs;orPTAs may also qualify if they are licensed, registered or certified as a PTA, if applicableand meet requirements in effect before January 1, 2008, that is,• they have graduated before January 1, 2008, from a 2 year college levelprogram approved by the APTA; or• on or before December 31, 1977, they were licensed or qualified as a PTA andpassed a proficiency examination conducted, approved, or sponsored by theU.S. Public Health Service.Services. The services of PTAs used when providing covered therapy benefits areincluded as part of the covered service. These services are billed by the supervisingphysical therapist. PTAs may not provide evaluative or assessment services, makeclinical judgments or decisions; develop, manage, or furnish skilled maintenance program services; or take responsibility for the service. They act at the direction and under thesupervision of the treating physical therapist and in accordance with state laws.A physical therapist must supervise PTAs. The level and frequency of supervision differsby setting (and by state or local law). General supervision is required for PTAs in allsettings except private practice (which requires direct supervision) unless state practicerequirements are more stringent, in which case state or local requirements must befollowed. See specific settings for details. For example, in clinics, rehabilitationagencies, and public health agencies, 42CFR485.713 indicates that when a PTA providesservices, either on or off the organization’s premises, those services are supervised by aqualified physical therapist who makes an onsite supervisory visit at least once every 30days or more frequently if required by state or local laws or regulation.The services of a PTA shall not be billed as services incident to a physician/NPP’sservice, because they do not meet the qualifications of a therapist.The cost of supplies (e.g., theraband, hand putty, electrodes) used in furnishing coveredtherapy care is included in the payment for the HCPCS codes billed by the physicaltherapist, and are, therefore, not separately billable. Separate coverage and billingprovisions apply to items that meet the definition of brace in §130.Services provided by aides, even if under the supervision of a therapist, are not therapyservices and are not covered by Medicare. Although an aide may help the therapist byproviding unskilled services, those services that are unskilled are not covered byMedicare and shall be denied as not reasonable and necessary if they are billed as therapyservices.D. Application of Medicare Guidelines to PT ServicesThis subsection will be used in the future to illustrate the application of the aboveguidelines to some of the physical therapy modalities and procedures utilized in thetreatment of patients.