Page 224 - Medicare Benefit Policy Manual

See section 220 of this chapter for definitions. Therapist refers only to a qualified
physical therapist, occupational therapist or speech-language pathologist. TPP refers to
therapists in private practice (qualified physical therapists, occupational therapists and
speech-language pathologists).

In order to qualify to bill Medicare directly as a therapist, each individual must be
enrolled as a private practitioner and employed in one of the following practice types: an
unincorporated solo practice, unincorporated partnership, unincorporated group practice,
physician/NPP group or groups that are not professional corporations, if allowed by state
and local law. Physician/NPP group practices may employ TPP if state and local law
permits this employee relationship.

For purposes of this provision, a physician/NPP group practice is defined as one or more
physicians/NPPs enrolled with Medicare who may bill as one entity. For further details
on issues concerning enrollment, see the provider enrollment Web site at
www.cms.hhs.gov/MedicareProviderSupEnroll and Pub. 100-08, Medicare Program
Integrity Manual, chapter15, section 15.4.4.9.

Private practice also includes therapists who are practicing therapy as employees of
another supplier, of a professional corporation or other incorporated therapy practice.
Private practice does not include individuals when they are working as employees of an
institutional provider.

Services should be furnished in the therapist’s or group’s office or in the patient’s home.
The office is defined as the location(s) where the practice is operated, in the state(s)
where the therapist (and practice, if applicable) is legally authorized to furnish services,
during the hours that the therapist engages in the practice at that location. If services are
furnished in a private practice office space, that space shall be owned, leased, or rented
by the practice and used for the exclusive purpose of operating the practice. For
descriptions of aquatic therapy in a community center pool see section 220C of this
chapter.

Therapists in private practice must be approved as meeting certain requirements, but do
not execute a formal provider agreement with the Secretary.

If therapists who have their own Medicare National Provider Identifier (NPI) are
employed by therapist groups, physician/NPP groups, or groups that are not professional
organizations, the requirement that therapy space be owned, leased, or rented may be
satisfied by the group that employs the therapist. Each therapist employed by a group
should enroll as a TPP.

When therapists with a Medicare NPI provide services in the physician’s/NPP’s office in
which they are employed, and bill using their NPI for each therapy service, then the
direct supervision requirement for enrolled staff apply.