PTAs & Discharge

Q: Can PTAs complete the discharge summary for home health patients or discharge home health patients from home care services?

A:  There are two types of discharges from a home health agency when a visit is made to the home: 1) A discipline discharge and 2) an agency discharge. Agency discharges require OASIS assessments to 
be completed for Medicare, Managed Medicare, Medicaid and many private insurances. 

Discipline discharges do not require OASIS, but are considered assessments by most states and Federal 
regulations under Medicare Part B. Under a PTA and COTA’s education, they cannot perform assessments. Discharge summaries are considered assessments.

However, some state scopes of practice allows for PTA and COTA to perform testing, report the results 
to the PT/OT overseeing the care plan, and have a collaborate note on the last visit that counts as a discharge summary although the final visit was made by a PTA or COTA. Scope of practice varies by the state (check with your state licensing entity for the relevant rules).

It is not a good practice, and may be interpreted as illegal when a PTA or COTA write discharge summaries 
(assessments) at the discharge. The question to ponder is how can they write opinion statements of status 
change? Legally, by education and law, they cannot. PT and OT should make the last visit to determine 
if the patients goals have been achieved and care plan is complete.

Looking for state licensing rules?

Federation of State Boards of Physical Therapy (Click on "Licensing Authorities")

PTA Supervision & Frequency

Q: My understanding is that supervision of the PTA must be done after the PTA makes 5-7 visits under Medicare home health guidelines.

A: This time frame should be based on the State Practice Act requirements, but it is not a Medicare regulation for the home health setting. Medicare has not established any rules related to frequency for supervision of the PTA by the PT in the home health setting.

You should refer to your state specific document first any time you have questions related to PTA supervision.

Additional resources (Please note that most of these resources require member login for access):

APTA resources related onPTA supervision

State Practice Act resources: Federation of State Boards of Physical Therapy


Starting a Home Health Agency

Q: I’m a physical therapist who wants to start my own home health agency. Where can I find information on how to do this?

A: Starting any kind of business is complex and there is not a simple "how to” list for starting a home health agency. That said, here are just a couple of suggestions about where you might begin to do your research on rules and regulations for creating a home health agency:

  1. Research your State’s requirements related to a certificate of need and/or home health agency licensing. This information is usually available through your State Department of Health (department names vary by state).
  2. Examine Medicare’s Application Process for Home Health Agencies
    • Before beginning the Medicare enrollment process, you must obtain your incorporation/EIN from the IRS and open a bank account in that entities’ name
    • Obtain NPI # prior to enrolling for Medicare Enrollment -https://nppes.cms.hhs.gov or call 800-465-3203.
    • Complete Medicare CMS-855A Enrollment Application to submit to the Medicare fee-for-service contractor servicing your state or location - A downloadable form can be obtained at http://www.cms.hhs.gov.
    • A list of Medicare fee-for-service contractors by State can be found in the download section of http://www.cms.hhs.gov/MedicarePRoviderSupEnroll//.
    • Be thorough and exact, call your intermediary agent with questions.
    • Submit EFT Authorization Agreement (CMS 588) with your enrollment application, as well as all other applicable supporting documentation. You must submit a cancelled check that shows the EXACT company name with your EFT agreement form (CMS 588) or your application will be rejected.
    • You are required to have enough reserve operating funds in the bank account to cover the HHA’s first 3 months of operations and at least 50% of the funds must be non-borrowed funds.
  3. Consider how you will market your agency.
    • Service area definition
    • Demographics of service areas
    • Resources for demographics
    • US Census Bureau
    • CMS
    • Claritas
    • Identify and research the competition (and consult them, if you can!)
    • Trade associations
    • Government agencies
    • Yellow pages
    • Healthcare Market Resources