Outpatient Physical Therapy/Outpatient Speech Pathology Services (OPT/OSP)
A. General Background Information
There are three types of certified providers of OPT/OSP services:
1. Rehabilitation Agencies – These facilities furnish services in a team environment and in accordance with a “multidisciplinary” program to assist handicapped and disabled individuals. They provide not only OPT/OSP services, but social or vocational adjustment services as well. (See CMS Pub. 100-07, chapter 2, section 2292A.) The overwhelming majority of Part A OPT/OSP providers are rehabilitation agencies.
2. Clinics – A clinic is created primarily for the provision of outpatient physician services. The entity’s services must be furnished by a group of at least three physicians practicing medicine together, and at least one physician must be present in the clinic at all times to perform medical services.
3. Public Health Agency – This is an agency created by a State or local government. Its primary purpose is to furnish environmental health services, preventive medical services and, in some instances, therapeutic services, as a means of sustaining the health of the general population.
Note that:
• If an OPT/OSP provider elects to convert to a comprehensive outpatient rehabilitation facility (CORF), it must meet the CORF conditions of coverage and participation. An initial Form CMS-855A enrollment application, State survey, and CMS regional office approval are also required.
• Only those clinics (as listed above) that provide OPT/OSP services have provider agreements under 42 CFR §489.2. Part B physician groups – the supplier type that most people normally associate with the term “clinics” – do not have provider or supplier agreements.
• Occupational therapy cannot be substituted for the physical therapy requirement. It may, however, be provided in addition to physical therapy or speech pathology services. (See Pub. 100-07, chapter 2, section 2292A.)
B. Extension Locations
As discussed in Pub. 100-07, chapter 2, section 2298A, an OPT/OSP provider can furnish services from locations other than its primary site. (The provider must designate one location as its primary location, however.) These sites are called extension locations. They may include freestanding offices, suites in an office or medical building, or even space in an existing Medicare provider, such as a skilled nursing facility or hospital. Yet the separate area of the host provider or facility must be set aside for the provision of OPT/OSP services during the hours of the OPT/OSP provider’s operations. (The area/room/unit would be considered the extension location..)
An OPT/OSP provider may also furnish therapy services in a patient’s home or in a patient’s room in a SNF. Because they are not considered extension locations, neither the home nor the patient’s room need be listed as a practice location on the provider’s Form CMS-855A. (See Pub. 100-07, chapter 2, section 2298B.)
For an OPT/OSP provider to establish an extension location in an adjoining State, the two States involved must have a signed reciprocity agreement with each other allowing approval of the extension location. An extension location situated in a different State will bill under the primary site’s provider number. (See Pub. 100-07, chapter 2, section 2302.)
C. Additional OPT/OSP Information
For more information on OPT/OSP providers, refer to:
• Section 1861(p) of the Social Security Act
• 42 CFR Part 485, subpart H
• Pub. 100-07, chapter 2, sections 2290 – 2306 (State Operations Manual)
• Pub. 100-07, Appendix E
A. General Background Information
There are three types of certified providers of OPT/OSP services:
1. Rehabilitation Agencies – These facilities furnish services in a team environment and in accordance with a “multidisciplinary” program to assist handicapped and disabled individuals. They provide not only OPT/OSP services, but social or vocational adjustment services as well. (See CMS Pub. 100-07, chapter 2, section 2292A.) The overwhelming majority of Part A OPT/OSP providers are rehabilitation agencies.
2. Clinics – A clinic is created primarily for the provision of outpatient physician services. The entity’s services must be furnished by a group of at least three physicians practicing medicine together, and at least one physician must be present in the clinic at all times to perform medical services.
3. Public Health Agency – This is an agency created by a State or local government. Its primary purpose is to furnish environmental health services, preventive medical services and, in some instances, therapeutic services, as a means of sustaining the health of the general population.
Note that:
• If an OPT/OSP provider elects to convert to a comprehensive outpatient rehabilitation facility (CORF), it must meet the CORF conditions of coverage and participation. An initial Form CMS-855A enrollment application, State survey, and CMS regional office approval are also required.
• Only those clinics (as listed above) that provide OPT/OSP services have provider agreements under 42 CFR §489.2. Part B physician groups – the supplier type that most people normally associate with the term “clinics” – do not have provider or supplier agreements.
• Occupational therapy cannot be substituted for the physical therapy requirement. It may, however, be provided in addition to physical therapy or speech pathology services. (See Pub. 100-07, chapter 2, section 2292A.)
B. Extension Locations
As discussed in Pub. 100-07, chapter 2, section 2298A, an OPT/OSP provider can furnish services from locations other than its primary site. (The provider must designate one location as its primary location, however.) These sites are called extension locations. They may include freestanding offices, suites in an office or medical building, or even space in an existing Medicare provider, such as a skilled nursing facility or hospital. Yet the separate area of the host provider or facility must be set aside for the provision of OPT/OSP services during the hours of the OPT/OSP provider’s operations. (The area/room/unit would be considered the extension location..)
An OPT/OSP provider may also furnish therapy services in a patient’s home or in a patient’s room in a SNF. Because they are not considered extension locations, neither the home nor the patient’s room need be listed as a practice location on the provider’s Form CMS-855A. (See Pub. 100-07, chapter 2, section 2298B.)
For an OPT/OSP provider to establish an extension location in an adjoining State, the two States involved must have a signed reciprocity agreement with each other allowing approval of the extension location. An extension location situated in a different State will bill under the primary site’s provider number. (See Pub. 100-07, chapter 2, section 2302.)
C. Additional OPT/OSP Information
For more information on OPT/OSP providers, refer to:
• Section 1861(p) of the Social Security Act
• 42 CFR Part 485, subpart H
• Pub. 100-07, chapter 2, sections 2290 – 2306 (State Operations Manual)
• Pub. 100-07, Appendix E
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