FAQs about the Occupational Therapist in Private Practice (OTPP

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Frequently Asked Questions
What is an Occupational Therapist in Private Practice (OTPP)?
An OTPP is an experienced therapist who has applied through the Centers for Medicare
and Medicaid Services (CMS) to provide therapy as an independent provider; CMS
credentials therapists as OTPPs, and gives them special privileges. These therapists are
given “freedom” regarding the location of service provision, are able to provide “stand
alone” services in the home, are able to participate in CMS’ Physician’s Quality
Reporting Initiative program, and may bill Medicare directly.
How is the OTPP different from a home health care therapist?
The home health care therapist is typically employed by or contracted with a home care
agency, and is only sent into the home when a patient qualifies for home health care
services. One of the essential criteria for receiving home health care is that the client be
considered homebound. Therefore, the scope and focus of the evaluation of the home
health therapist is essentially different from that of the OTPP; the OTPP works from a
model of practice that addresses functional concerns not only in the home but also in
the community. The home health care therapist is limited to addressing the
homebound needs of a patient; the home health care evaluation focuses on the client’s
ability to function in the home (not outside of the home).
In the majority of home health care agencies, a therapist does the evaluation, but a
Certified Occupational Therapy Assistant (COTA) provides the treatment. The COTA is
a technical level practitioner. Clients served by OTPPs receive all intervention from a
professional therapist; no COTAs are permitted to serve in this model. The cost of
services to the payer is the same, however, the client receives the professional
therapist’s expertise at all sessions; in home care, the technical level practitioner often
provides the majority of services. Therefore, the therapeutic intensity of the OTPP
sessions is expected to be greater since a professional therapist is monitoring and
grading each session
Clients who have short term needs, or who can quickly return to a prior level of
function through a brief episode of therapeutic intervention may be satisfied with the
services of a therapist (or therapy assistant) from a home care agency. Clients who are
homebound, and who have a reached a state of health where they are not expected to
ever return to a non-homebound status, also may best be served by a home health care
therapist or OT assistant.
The OTR in Private Practice is prepared to establish an on-going relationship with a
client. Clients are able to call the OTPP if a need arises after discharge; the OTPP is able
to contact the physician, and with physician approval, may re-enter a case without any
other skilled service. This is significantly different from the home health care model
where OT can only enter a case behind the nurse or physical therapist
How is the OTPP different from an out-patient therapist?
Out-patient therapists typically focus on the physical, cognitive, and psychological
impairments in a client’s clinical picture. The OTPP not only addresses these, but also
incorporates the environment (social and physical) into the intervention plan.
The OTPP thrives on helping clients successfully and safely participate in meaningful
activities in the natural environment. The OTPP uses “drills” infrequently; the natural
environment (home and community) provides a rich and motivating therapeutic milieu
for the OTPP to use as a part of the intervention program. Out-patient therapists must
use media that resemble aspects of activities the client is struggling to resume; the OP
therapist can only guess at the impact of the home environment (positive or negative)
on the client’s performance.
Out-patient clinics employ both OTRs and COTAs. OTRs perform evaluations;
frequently patients receive therapy from COTAs when seen in the OP clinic. When
clients choose the OTPP, he or she receives the professional care of a therapist at every
session. Again, therefore, the therapeutic intensity of the program can be expected to
be greater when using the OTPP, since this model utilizes ONLY therapist.
The one advantage the out-patient OT clinic offers is an efficient environment for
splinting or casting. The OTPP understands this advantage, and invites clients to hold
sessions at the clinic when orthotics must be fabricated.
How do the services of the OTPP differ from those provided by home care
therapists or out-patient therapists?
In summary, the OTPP provides clients with a stable, therapeutic relationship in the
home, in the community, and/or in the out-patient clinic. The therapist determines the
best environment for intervention, and provides it there. The OTPP is able to provide
services to the client when the individual is in the “gray” area; that is, the client may be
afraid of leaving the home, or may be depressed and dis-engaged from participating in
activities outside the home, although the client is not technically homebound.
Unfortunately, without skilled services, some of these clients may become homebound.
In addition, clients served by OTPPs always receive intervention by a professional
therapist; in home care agencies and in out-patient clinics, clients are typically
evaluated by a professional therapist and receive intervention an Occupational Therapy
Assistant (OTA). Medicare does not permit Occupational Therapy Assistants to be
credentialed as OTPPs. When a consumer chooses to use an OTPP, the evaluation and
all of the intervention is provided by a professional therapist.
Where can an OTPP treat a client?
CMS coverage rules state that the OTPP can provide services “in the home or the clinic.”
This basically creates a special type of health care delivery provider; the home health
therapist can ONLY treat in the home, and the out-patient therapist does NOT treat in the
home. The OTPP is free to serve the client in the environment that will be most effective
in facilitating change and achieving functional outcomes.
The home health care therapists work under the Part A rules that require the client to
be homebound. If a home health care provider progresses a client to a non-homebound
status, the client “graduates” from their care. In the larger picture, the incentive to
progress a client is in conflict with the desire to serve the client; clients who become
non-homebound must be discharged from the care of the home health care provider.
Most home health care therapists care very much for their clients, and are willing to
work themselves out of a job. It is sometimes presents a conflict of interest for clients,
however, who understand that if they progress to being non-homebound that they will
have to find another therapist to continue the rehabilitation process.
What is the advantage of using a home and community-based OTPP?
Continuity- The home and community based OTPP becomes a client’s therapist, much in the same way a
physician becomes a “client’s doctor.” There are advantages in maintaining a relationship with one
health care provider who understands the unique complexities and circumstances of a patient’s situation.
Since the OTPP can cross-over from home to clinic, the client does not have to switch therapists as he or
she progresses in care.
Follow-up- The OTPP can establish a functional maintenance plan for a client, and provide intermittent
follow-up to assure that a client has not lost ground in the rehabilitation effort once skilled services were
stopped. The OTPP often gets to know a client well can recognize small declines that may be harbingers
of increased risk of falls; falls prevention is a major area of intervention for our practice with the elderly.
Return to prior level of function- Occasionally, after a program has been completed and a client
discharged, additional problems arise in a client’s life that necessitate therapeutic intervention. A Client
who has an OTPP in his or her life is able to have the same therapist provide care; the intervention plan is
more quickly established because the OTPP has a clear picture of the prior level of function.
Real environment- Whereas some out-patient clinics go to great lengths (and cost) to establish
simulated environments to challenge or train a client, the OTPP has the privilege of using the real
environment (home and community) in which a client lives. The use of the actual home and community
environment eliminates the need for generalization of skills; it also enables the therapist to consider
environmental cues or modifications that can support successful participation in activities.
Network in community- When needed, the OTPP provides skilled services to assist clients transition
to supported living situations (independent living/assisted living) or to adult day programs in the
community. The skilled services of an OTPP can help clients and families recognize a person’s strengths
and weaknesses, and make informed choices regarding available support systems in the community.
FAQs about the Occupational Therapist in Private Practice (OTPP)
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Do Medicare Advantage programs use the services of an OTPP?
Yes. OTPPs are enrolled in MA programs as out-patient therapists; they are unable to
enroll as “home health therapists” because they are not part of a home health care
agency. As explained in an earlier question, however, Medicare rules permit OTPPs to
provide services in either the home or the clinic. This has caused some confusion in
billing/coverage, because MA plans enroll providers by their location (out-patient vs
home health).
Since Medicare credentials OTPPs, and Part B rules permit OTPPs to treat the client in
the home or clinic, Medicare Advantage programs that enroll these therapists have the
“advantage” of having a therapist who is prepared to serve a client at home, in the
community, or in the clinic.
Doesn’t a client have to be homebound in order to receive services in the home?
Not always. Under Part A coverage rules, the client must be homebound. Part A Home
health care benefits are ONLY available to the homebound beneficiary.
Under Part B rules, the OTPP can provide skilled services in the home to clients who are
NOT homebound.
Why would an OTPP want to treat a person in the home instead of in a clinic?
Because the focus of Occupational Therapy is to support a person’s ability to engage in
meaningful activities, evaluating and treating a person IN THE ENVIRONMENT where
these occupations occur is typically the most efficient and effective approach. For the
OTPP, the home is a virtual paradise of a meaningful environment with familiar objects
and real-life challenges.
The objects and furniture in a person’s living environment are USED as part of the
therapeutic intervention program; for each client it is different. The OTPP works with
clients to establish goals related to maximizing independence and promoting safety in
the home environment.
Can a client receive Occupational Therapy services from an OTPP without
receiving Physical Therapy or Skilled Nursing?
YES! The OTPP can provide the sole skilled service, if that is what a client needs. This is
a Part B benefit. OT can “stand alone” from being to end, if that is all the client needs.
Under Part A guidelines, when care is provided by a home health care agency, a
qualifying skilled service, either Physical Therapy or Skilled Nursing, must open the
case; Occupational Therapy is not considered a qualifying skilled service under Part A
benefits (Editor’s note- there is currently legislation under consideration to change
this).
FAQs about the Occupational Therapist in Private Practice (OTPP)
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Can a client receive Occupational Therapy in the home and Physical Therapy in
the clinic?
YES, if you can find an OTPP who works with an out-patient Physical Therapy Clinic.
For many clients, that is the best of both worlds. The OTPP can address the
environmental issues in the home, and the Physical Therapist can use clinic-based
equipment to help a client achieve the PT-oriented goals.
When is an OTPP really needed?
An OTPP is the “best choice” for clients who are not homebound, and/or who do not
want to be homebound. Clients whose prior level of function was NOT homebound, and
who are experiencing depression related to the isolation of not being able to get out
into the community, may benefit from having a therapist prepared to provide skilled
services to move them OUT of the home.
The OTPP is an excellent choice for any client who:
•is cognitively impaired
•has low vision impairments
•has significant physical impairments
•is struggling to live safely and independently in his or her home
•is depressed and in need of a program to support re-engagement in meaningful
occupations (at home and in the community)
•is at risk for falls.
Why is the OTPP the best choice for a client who is at risk for falls?
The evidence in falls prevention programs points to “internal” and “external” factors
that need to be addressed. Out-patient balance clinics may address some of the internal
factors, but cannot address the environmental factors present in the client’s home or
community.
The OTPP is able to address both the internal and the external factors related to falls
prevention.
FAQs about the Occupational Therapist in Private Practice (OTPP)
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Who are the OTPPs at the Rehabilitation and Health Center (RHC) at Park West?
We are the premier group of OTPPs in the Greater Akron area. There are six OTRs in
our group; all of us are credentialed by CMS, and in network with all the major
insurance companies in our area.
Carolyn Bousfield MS, OTR/L, OTPP
Brenda Marvel, OTR/L, OTPP
Cheryl Minor OTR/L, OTPP
Susan L Shah, OTR/L, OTPP
Marie Van Devere OTR/L, OTPP
Mary Jo McGuire MS, OTR/L, OTPP, FAOTA
Mary Jo McGuire, MS, OTR/L, OTPP, FAOTA is the founder of the group; she has over 30
years of experience as an Occupational Therapist. She serves as a member of the Ohio
Occupational Therapy Medicaid Task Force; she represents the American Occupational
Therapy Association on a national task force serving CSC, a company hired by CMS to
explore “Alternatives to the Caps” (Part B reimbursement); she is a member of the
Older Adults Member Service Group for the Ohio Occupational Therapy Association, and
authored the last chapter of AOTA’s recent book titled, “Strategies to Advance
Gerontological Excellence.”
For more information
Mary Jo McGuire MS, OTR/L, OTPP, FAOTA
Director of Home and Community Based Services
The Rehabilitation and Health Center
1 Park West Blvd., Suite 320
Akron, Ohio 44320
330.564.4100
mjm@TherapyInAkron.com
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