Posted by: Robert Markette
December 16, 2005

On November 1, 2005 FSSA published a proposed rule in the Indiana Regsiter.  This proposed rule amends 405 I.A.C. 5-22-8.  The purpose of the amendments is to clarify that Medicaid will reimburse for services provided by Physical Therapy Assistants.  As many home care providers in Indiana are aware, last summer the Office of Medicaid Policy and Planning made it clear that it did not believe the Mediciad regulations allowed providers to use PTA’s to provide services.  Of course, this did not make a great deal of sense either practically or fiscally. 

Under the PT practice act, PTA’s are clearly allowed to administer therapies as long as they are directly supervised by a PT.  FSSA had taken this concept a step farther and required direct “on-site” supervision.  Of course, on-site supervision mean that home health agencies had to use PTs for all services.  Allowing a PTA to provide the care after the licensed PT developed the care plan is not only completely acceptable under the PT regulations, but is very similar to the normal medical care model where the physician creates the plan of care and the nurses and other professionals and para-professionals implement the plan. 

Furthermore, for a cash strapped state like Indiana, it makes a lot of sense to allow the provider to use an assistant such as a PTA and then reimburse at a lower rate.  In this way, the patient receives the care needed, but the state uses a lower cost caregiver.

It appears that FSSA has recognized this and is now changing the Medicaid regulations to reflect this reality.  The proposed revision to 405 I.A.C. 5-22-8 would strike the “on-site” language and add language that specifically approves the use of certified physical therapy assistants.

The proposed rule would also adopt a specific reimbursement for services provided by certified PTAs.  The reimbursement would be set at 75% of the physician’s or LLP’s rate.  FSSA bases this rate upon the general rule that mid-level practicioners are reimbursed at 75% of the rate physician’s receive. 

The public hearing on this rule was held on November 22, 2005. 

One issue that FSSA has not addressed in this proposed rule is the use of OT assistants.  FSSA takes a similar position on the use of OT assistants in Medicaid.  Hopefully, Indiana will be rectifying this problem in the near future.

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