 instance, "supervising therapist present and assisting with all portions of treatment". Could a statement like this lay any suspicions to rest?
What needs to be emphasized to CMS is that every licensed therapist is responsible for their student and we have documents and guidelines for different types of supervision.
Student services are provided under the therapist's professional license. No one wants to put their professional license at risk. That is how we ensure quality. Student skills and clinical decision making abilities are verified by the supervising therapist prior to progressing independence.
In the past we have received definitions and guidelines for different levels of supervision (direct, indirect, on site, line of sight).
SNF Y1 : recommendations state "Reimbursable: Therapy students are not required to be in line-of-sight of the professional supervising therapist/assistant (Federal Register, August 8, 2011).
SNF: PTA student: Y2 "Reimbursable : minutes of student services count on the minimal data set"
Perhaps the same resources used to create this chart should be brought out and presented to CMS again?
Students "observe" and act as a "2nd pair of hands" PRIOR to therapy school as volunteers who are considering entering the profession. Preventing students from demonstrating that they can independently manage all aspects of patient care is not beneficial to the future of our profession or our patients.
I share many of the concerns expressed already regarding how we can continue to operate a clinical education program and prepare students for practice. I would like to offer an example from today of just one instance how this has already negatively affected the care to one of our patients. I currently have a Medicare patient that got a late start for her appointment due to nursing needs. My student and I saw the patient for 30 out of 45 minutes before we needed to move on to our next Medicare patient. In stead of my student seeing our first patient for an additional 15 minutes (for balance exercises that we had previously discussed) and overlapping with our second patient we cut her session short and she was returned to her room. This poor woman missed out on therapy that she desperately needs and is very motivated to participate in. This change in policy has already been detrimental to us providing our patient with the care that they need.
On a side note, Lieutenant General Michael Nagata's 2018 lecture "Leadership in a Rapidly Changing World." could not have been more timely.
Update on timing of the meeting between CMS, APTA, AOTA and ASHA: this is scheduled for the week of December 10.
I can only hope that the conversation with CMS the week of 12/10 does not end with the suggestion to document that the therapist was in the room the entire time with the student and patient.
This would be a concession to requiring "line of sight" supervision, and we should instead be referring to our state practice acts and professional guidelines for various appropriate levels of supervision. Requiring "line of sight" takes away the professional educator's discretion and does not account for the various levels of training and independence that students demonstrate.
Line of sight supervision requirements for entire therapy sessions would greatly reduce the number of students accepted on clinicals.
I agree. If a statement were to be required in the medical record something along the lines of "plan and treatment discussed with physical therapist prior to implementation" would be a much better alternative to foster the development of our studnets to allow them to be better equipped to work with Medicare recipients as future licensed PT's.
Folks, As stated numerous times above: CMS, Medicare and all stakeholders are looking closely at this and other issues. Thank goodness. The trust with which we are imparted needs close scrutiny as well, the patients, students and each of us in "Healthcare" today. If any one of us "paid out-of-pocket for our services, I would like think we'd value those same services to the extent of the cost. (Does everyone know what CMS pays for one of your 15 minute units?) Without scrutiny and growth we could never make progress or serve the complex needs of our populations. That said, I hope any rare facilities exploiting students and doing "the worst case scenarios" are exposed and stopped. We've all heard stories of student and CI with two caseloads being billed or "off-site" supervisors... I am fortunate to work for a facility of high integrity, a teaching hospital where the quality is of much greater value and focus than the "quantity". Here we provide one-on-one, direct supervision to students in PT, OT, and SLP. It is rare to by outside line-of-sight, never out of direct verbal reach. (not by pager/iPhone/Vocera or other indirect electronic connection) I have been a CI in PT for 19 years, performed "remedial" education for students who were not "performance art" oriented or may have been nervous with a CI in the room. In those rare cases, my demeanor allowed them to select early treatments they were comfortable with delivering, and I would work directly to ensure that even awkward students were involved in treatment in "Qualified Manner". With my close proximity and immediate knowledge of both pt and student, I could allow failures. learning and teaching moments to evolve regularly in excellent, meticulously guarded safety. Any facility worried about more stringent laws or oversight, should perhaps look at their own practices.
Lastly, be aware that any "differential treatment" of patients based on their "Third Party provider" could constitute a breach of Ethical guidelines or potentially slip onto the slopes of fraud.
Our facilities host about a hundred PT, OT and SLP students on their graduate school clinical affiliations each year. It is our understanding that these students may treat patients under the guidance and direct supervision of their clinical instructors. I understand that under APTA student practice guidelines, students are required to have line of sight supervision. At our clinics, we take a more direct supervision approach. The licensed therapist dictates the treatment and plan of care for the patient and is present throughout the entire session.
If students do not have hands on experience, then how are they to learn? Student treatment under the supervision of a qualified practitioner is how our students learn and grow to be qualified practitioners when they graduate. If they are not allowed to have hands on experience and practice documentation in the medical and clinical setting, then they will not be prepared to be a licensed therapist and treat patients when they graduate.
I have emailed CMS my concerns and I am looking forward to hearing more soon AND before our influx of new students in 2019!
Thanks to everyone for the thoughtful feedback and perspectives. We have compiled these comments and passed them along to individuals at APTA who will be meeting with CMS representatives during the week of December 10. We will look forward to the outcome of these discussions and will participate in dissemination of an update to the community once we have more clarification on the implications of the regulations on the role of students.
I'm sure when information is available it will be posted, but hoping someone on this thread may have an update from the meeting with CMS? Pending a change in direction from CMS, my organization has limited IPR student rotations to observation only. We have several students slated for a rotation start date of January 1, 2019. So far, the universities we are contracted with are waiting to hear on the results of this meeting prior to attempting to find new placements.
The meeting with CMS staff was collegial.
CMS confirmed that there has been no policy change this year on the use of students.
CMS confirmed their support for clinical education for students.
CMS agreed to provide additional clarification in writing to us in a very short timeline.
See the previously issued Joint Statement from AOTA, APTA, ASHA on the Use of Students in Hospitals for background information. Watch the AOTA website for updates on CMS’s written clarification, which AOTA will share as soon as it is received. Please direct any questions to |||EMAIL_ADDRESS||| Senior staff from APTA, AOTA, and ASHA met with CMS officials on December 11, 2018. During this collegial meeting, CMS staff confirmed verbally that there has been no policy change in 2018 on the use of students. CMS also reaffirmed its support for clinical education. CMS concluded the meeting by agreeing to provide additional clarification in writing on this topic in the very near future.
Daughters without Fathers Struggle life!
Adjusting: Fathers, do you know your child self-esteem depends on dad being available for you? As a matter of fact, children feel Shattered and torn when many absentee parents don’t look back. Daughters without fathers are left feeling abandoned & hollow and reaching out to anyone for love. Moreover, any man that tells her she is beautiful, smart and funny.
And he will protect her, listens to her and makes her feel strong. Only a real dad will understand.
Fathers Love in other places.
Daughters without Fathers has a harder time adjusting to life.
In the first place, just being the strong, funny, supportive male role model. And girls like her yearning for the positive attention of a daddy will come running. Hoping the young woman will recognize this guy’s his motives before it’s too late. Hope she does not fall for his charm and his tricks. And let him lead her down a road to self-harm and abuse.
Meanwhile, once again another, later precious female will have been abandoned. By the one man in her life who was supposed to stand up for her. Against scumbag like this.
Daughters without Fathers in the home feel loss.
In reality, In a world of half-exposed female celebrity role models. Inthe media in birthday suit. Unfortunately, our girls are getting thewrong message about their value and self worth. The fact thatDaughters without fathers reiterates the message: that hisdaughter is not worth it. Or valuable enough