PTA and OTA Participation in TRICARE: The Process is Underway

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Original story posted on: January 16, 2019

Military healthcare program expanding coverage following extensive lobbying campaign.

The U.S Department of Defense has signaled the start of the process to authorize physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) as TRICARE providers. This mandate was specified under Section 721 of the 2018 National Defense Authorization Act (NDAA).

Physical therapists (PTs) and occupational therapists (OTs) are currently authorized providers under TRICARE. The therapy industry was largely aware of the TRICARE regulations on the prohibition of cost sharing in private practice settings. Nearly two years ago, however, TRICARE signaled to the therapy community that the prohibition on the use of PTAs and OTAs extended to all settings, including hospitals, Skilled Nursing Facilities (SNFs), rehab agencies, and Comprehensive Outpatient Rehabilitation Facilities (CORFs). 

Lobbying by the therapy community and national therapy organizations to members of Congress throughout 2017 was successful in obtaining language in the 2018 NDAA to direct TRICARE to add PTAs and OTAs as authorized providers. And so, the journey took a first tiny step, with words of caution that the process might take as long as two years.   

It has been a year now, and we are on the way, with the Notice of Proposed Rule Making (NPRM) being issued. What is the expected timeline? Comments on the Proposed Rule are due Feb. 19, 2019. There is optimism that the process may be completed sometime this year – so the two-year estimate may be accurate.

Comments can be submitted via mail (see address in the Proposed Rule) or via the Federal Rulemaking Portal. At first glance, there are a few items in the rule requiring correction and clarification. These include the following:

  1. There is an incorrect reference to PTAs as “physical therapy assistants” rather than “physical therapist assistants.”

  2. There is reference to Medicare supervision requirements that describe “direct” supervision as “in the room,” rather than “in the office suite,” as defined in the Medicare Benefits Policy Manual, Sections 220-230 of Chapter 15, for therapy services.

  3. There are statements regarding billing for PTA and OTA services under the TRICARE- authorized supervising physical or occupational therapist’s provider identification (ID). Therapists working in facility settings are not individually enrolled in TRICARE, and the claims are submitted by the facility (e.g., hospital).

Access the Proposed Rule - Contact the American Physical Therapy Association (APTA), American Occupational Therapy Association (AOTA), the National Association or Rehabilitation (NARA), or other therapy advocacy groups for guidance on comments. If your practice or facility services the TRICARE community and you have been challenged by the inability to use qualified PTAs and OTAs to meet patient needs and scheduling in the past, this is a great opportunity to be heard.   

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Nancy J. Beckley, MB, MBA, CHC

Nancy Beckley is founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, and private practices. Nancy is certified in healthcare compliance by the Healthcare Compliance Certification Board. She is on the board of the National Association of Rehabilitation Providers and Agencies. She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities. Nancy is a familiar voice on Monitor Mondays, where she serves as a senior national correspondent.

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