PPS and APTA sent a letter to HHS Secretary Azar and CMS Administrator Verma to strongly encourage HHS and CMS to immediately take additional steps to ensure patient safety and protect health care providers by waiving two additional program requirements:

1. Eliminate the plan of care signature requirement during the COVID-19 pandemic.  This is necessary because during normal circumstances compliance with the physician signature requirement imposes a significant logistical and administrative burden for both therapy providers and physicians, taking valuable time and resources away from delivering patient care.  Waiting for a plan of care certification can force delays of clinically significant care.

2. Recognize the value and benefit of modifying the supervision requirement from direct to general supervision for physical therapist assistants in private practice settings, as such modification would better promote unrestricted, non-delayed access to therapy interventions.  Without a waiver of this limitation, a PTA may treat Medicare beneficiaries only during the hours when the physical therapist is present.  Therefore, during the COVID-19 crisis, a private practice is severely limited if the supervising physical therapist is sick or in quarantine. Furthermore, this prevents staff from practicing a form of social distancing where only some staff physically attend work each day, because the policy requires the physical presence of the physical therapist in order for the physical therapist assistant to do their job.

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