Clarification of Requirements for Off-Premises Activities and Approval of
Extension Locations for Providers of Outpatient Physical Therapy (OPT)
and Speech-Language Pathology Services and Off-Premises Activities
Guidance Updated: The Centers for Medicare & Medicaid Services (CMS) has added guidelines to the State Operations Manual (SOM)
Chapter 2 to clarify certification requirements for providers of OPTs.
• Off-Premises Activity: OPTs may only provide services at off-premises locations, such as ALFs/ILFs, on an intermittent basis
when there is no ongoing or permanent presence of the OPT.
• Two Person Duty Requirement: We are clarifying that a patient’s room, and by extension, common areas within an assisted
living facility (ALF) or independent living facility (ILF) may be considered a patient’s residence and may be exempt from
the OPT two-person duty requirement.
• Extension Location Approval and Administration Requirement: Extension locations may be approved when they are located outside
the immediate vicinity of the primary site.