Page 219 - Medicare Benefit Policy Manual

• completed certification requirements to practice as an OTA established by a
credentialing organization approved by AOTA; and

• after January 1, 2010, they have also completed an education program accredited
by ACOTE and passed the NBCOT examination for OTAs.

OTAs who qualified under the policies in effect prior to January 1, 2008, continue to
qualify to provide OT directed and supervised OTA services to Medicare beneficiaries.
Therefore, OTAs qualify who after December 31, 1977, and on or before December 31,
2007:

• completed certification requirements to practice as an OTA established by a
credentialing organization approved by AOTA; or

• completed the requirements to practice as an OTA applicable in the state in which
practicing.

Those OTAs who were educated outside the U.S. may meet the same requirements as
domestically trained OTAs. Or, if educated outside the U.S. on or after January 1, 2008,
they must have graduated from an OTA program accredited as substantially equivalent to
OTA entry level education in the U.S. by ACOTE, its successor organization, or the
World Federation of Occupational Therapists or a credentialing body approved by
AOTA. In addition, they must have passed an exam for OTAs administered by NBCOT.

Services. The services of OTAs used when providing covered therapy benefits are
included as part of the covered service. These services are billed by the supervising
occupational therapist. OTAs may not provide evaluative or assessment services, make
clinical judgments or decisions; develop, manage, or furnish skilled maintenance program
services; or take responsibility for the service. They act at the direction and under the
supervision of the treating occupational therapist and in accordance with state laws.

An occupational therapist must supervise OTAs. The level and frequency of supervision
differs by setting (and by state or local law). General supervision is required for OTAs in
all settings except private practice (which requires direct supervision) unless state
practice requirements are more stringent, in which case state or local requirements must
be followed. See specific settings for details. For example, in clinics, rehabilitation
agencies, and public health agencies, 42CFR485.713 indicates that when an OTA
provides services, either on or off the organization’s premises, those services are
supervised by a qualified occupational therapist who makes an onsite supervisory visit at
least once every 30 days or more frequently if required by state or local laws or
regulation.

The services of an OTA shall not be billed as services incident to a physician/NPP’s
service, because they do not meet the qualifications of a therapist.