Page 217 - Medicare Benefit Policy Manual

The new personnel qualifications for occupational therapists (OT) 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 this rule, published in the Federal Register on
January 15, 2008.

The regulation provides that a qualified OT is an individual who is licensed, if licensure
applies, or otherwise regulated, if applicable, as an OT by the state in which practicing,
and graduated from an accredited education program for OTs, and is eligible to take or
has passed the examination for OTs administered by the National Board for Certification
in Occupational Therapy, Inc. (NBCOT). The phrase, “by the state in which practicing”
includes any authorization to practice provided by the same state in which the service is
provided, including temporary licensure, regardless of the location of the entity billing
the services. The education program for U.S. trained OTs is accredited by the
Accreditation Council for Occupational Therapy Education (ACOTE). The requirements
above apply to all OTs effective January 1, 2010, if they have not met any of the
following requirements prior to January 1, 2010.

The OTs may also qualify if on or before December 31, 2009:

• they are licensed or otherwise regulated as an OT in the state in which practicing
(regardless of the qualifications they met to obtain that licensure or regulation);
or

• when licensure or other regulation does not apply, OTs have graduated from an
OT education program accredited by ACOTE and are eligible to take, or have
successfully completed the NBCOT examination for OTs.

Also, those OTs who met the Medicare requirements for OTs that were in 42CFR484.4
prior to January 1, 2008, qualify to provide OT services for Medicare beneficiaries if:

• on or before January 1, 2008, they graduated an OT program approved jointly by
the American Medical Association and the AOTA, or

• they are eligible for the National Registration Examination of AOTA or the
National Board for Certification in OT.

Also, they qualify who on or before December 31, 1977, had 2 years of appropriate
experience as an occupational therapist, and had achieved a satisfactory grade on a
proficiency examination conducted, approved, or sponsored by the U.S. Public Health
Service.

Those educated outside the U.S. may meet the same qualifications for domestic trained
OTs. For example, they qualify if they were licensed or otherwise regulated by the state
in which practicing on or before December 31, 2009. Or they are qualified if they: