When providing services to Medicare patients, can the different disciplines (i.e. PT, OT, Speech) use assistants or aides and have those minutes count towards MDS and establish a RUG score?
Answer
Unfortunately the rules are not necessarily intuitive and there are MANY of them. Assistant level personnel, which is someone who has an Associate’s degree equivalent and generally a state license, can provide services within the Medicare program. However aides, rehab aides, or rehab technicians are generally support personnel that do not require any specific education or licensure. Service delivery minutes provided by an aide are not counted towards MDS provided minutes. MDS provided minutes drive the RUG score in a skilled nursing setting. That is an area where guidelines are in conflict. Most states will say that a physical therapist or occupational therapist is operating within their scope of practice if they are supervising treatment provided by an aide. But a Medicare program that is looking at service delivery minutes would not count those minutes towards the total that establishes a RUG score. However, assistants who have a license and have a certification or degree do provide minutes that are counted towards the MDS and establishing a RUG score. Medicare does not recognize assistants in speech. They do recognize assistants in PT and OT.
Ms. O’Hara is a speech-language pathologist with 17 years experience in the development and management of multidisciplinary therapy departments. As a documentation and Medicare reimbursement specialist as well as clinical director, she views rehabilitation as a dynamic entity with infinite potential.
Lorelei O'Hara, M.A., CCC-SLP
Ms. O’Hara is a speech-language pathologist with 17 years experience in the development and management of multidisciplinary therapy departments. As a documentation and Medicare reimbursement specialist as well as clinical director, she views rehabilitation as a dynamic entity with infinite potential. Ms. O’Hara spent several years living in England where she worked for the National Health Service, which further advanced her appreciation of the contribution of excellent rehabilitation teams.
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