Implementing General Supervision for Therapy Assistants

One of the most significant (and welcomed) updates to Medicare regulations for 2025 is the permanent adoption of general supervision for therapy assistants in private practice settings.

If you employ physical therapist assistants (PTAs) or occupational therapy assistants (OTAs), this change can streamline your operations, improve access to care, and give your clinic more flexibility—without sacrificing compliance or patient outcomes.

As a medical billing partner supporting therapy practices nationwide, we're excited to help you understand what this change means, and how to make the most of it.

🔍 What Changed?

Historically, direct supervision was required in outpatient private practice settings. That meant the supervising therapist had to be physically present in the office suite while the assistant provided care—even if they weren’t in the same room.

Now, thanks to the Consolidated Appropriations Act of 2023, CMS has finalized a permanent shift to general supervision. This was initially a temporary measure during the COVID-19 public health emergency—but now it’s here to stay.

Under general supervision:

• The supervising therapist does not need to be physically present on-site

• They must be available by phone or other means and have directed the care plan

🧠 Why It Matters to Your Practice

Let’s be honest—direct supervision can be limiting. Whether you're juggling patient loads, managing multiple locations, or working with a hybrid team, being tied to one physical location slows everyone down.

Here’s how general supervision helps:

• ✅ Greater flexibility for scheduling — Therapists and assistants can work in different locations.

• ✅ Improved staff utilization — You can deploy PTAs more efficiently without the burden of constant in-person oversight.

• ✅ Expanded access to care — Especially in rural or underserved areas where providers are stretched thin.

• ✅ Potential cost savings — Frees up therapists to see more complex cases while assistants manage follow-ups.

🛠️ How to Implement General Supervision in Your Practice

It’s not just about changing where people work—it’s about implementing the right systems to ensure compliance and consistency.

1. Update Policies and Procedures

Make sure your documentation clearly defines:

• The roles of PTs and PTAs

• When general supervision applies

• How therapists will remain available for consults

2. Enhance Communication Protocols

Supervising therapists must still be involved in treatment planning and available when assistants are treating.
Establish systems like:

• Weekly case review meetings

• Shared treatment notes and alerts in your EHR

• Real-time communication tools (phone, secure messaging)

3. Educate Your Team

Your PTs, PTAs, and billing staff all need to understand what general supervision means and how it works under Medicare. Misunderstandings can lead to billing errors or compliance risks.

4. Align Your Billing Practices

Even though supervision has changed, billing rules for assistant services remain the same, including:

• Proper use of modifiers CO (PTA) and CQ (OTA)

• Payment reduction still applies for services provided in whole or in part by assistants (85% of the fee schedule rate)

A good billing team will track and apply these automatically—but don’t assume your software or clearinghouse is catching it for you.

🧾 Billing Example

A PTA conducts a therapeutic exercise session (CPT 97110) under general supervision.

• Bill the service under the supervising PT’s NPI

• Append modifier CQ to indicate the service was provided by a PTA

• Medicare reimburses at 85% of the standard rate for that code

🚀 Ready to Optimize?

The shift to general supervision is more than a regulatory change—it’s an opportunity to operate more efficiently and expand your impact.

However, it also brings increased responsibility for clear documentation, communication, and proper billing. That’s where we come in.

As a medical billing company that specializes in therapy practices, we’ll help you:

• Adjust your workflows for compliance

• Ensure accurate modifier use

• Maximize reimbursement even with reduced assistant rates

• Keep up with Medicare updates that impact your revenue

Questions about how this applies to your practice?
Let’s connect. We’ll walk through your current structure and help you implement general supervision the right way.