Outpatient Rehabilitation Providers

This page provides basic information about being certified as a Medicare and/or Medicaid provider of outpatient therapy and includes links to applicable laws, regulations, and compliance information.

There are three types of organizations that may qualify as OPT/OSP providers:

1. Rehabilitation Agency - An agency that provides an integrated, multidisciplinary program designed to upgrade the physical functions of handicapped, disabled individuals by bringing together, as a team, specialized rehabilitation personnel. 
2. Clinic - A facility established primarily for the provision of outpatient physicians’ services. To meet the definition of a clinic, the facility must meet the following test of physician participation:
   • The medical services of the clinic are provided by a group of three or more physicians practicing medicine together; and
   • A physician is present in the clinic at all times during hours of operation to perform medical services (rather than only administrative services).
3. Public Health Agency - An official agency established by a State or local government, the primary function of which is to maintain the health of the population served by providing environmental health services, preventive medical services, and in certain instances, therapeutic services.

In order for clinics, rehabilitation agencies, and public health agencies to be eligible to participate as providers of OPT/OSP services, they must be in compliance with all applicable Medicare requirements, except the following: 42 CFR 485.709, Administrative Management, is not applicable to public health agencies, and 42 CFR 485.717, Rehabilitation Program, is not applicable to clinics or public health agencies.

During the course of the State survey, it verifies that the services that the provider proposes to offer are actually being provided. The State Agency evaluates the cumulative records of services actually provided. Work schedules of personnel providing services will show utilization data for various services.

Outpatient Rehabilitation

Survey protocols and Interpretive Guidelines are established to provide guidance to personnel conducting surveys. They serve to clarify and/or explain the intent of the regulations and all surveyors are required to use them in assessing compliance with Federal requirements. The purpose of the protocols and guidelines is to direct the surveyor’s attention to certain avenues for investigation in preparation for the survey, in conducting the survey, and in evaluation of the survey findings.

The Outpatient Physical Therapy/Outpatient Speech Pathology (OPT/OSP) survey is conducted in accordance with the appropriate protocols and substantive requirements in the statute and regulations to determine whether a citation of non-compliance is appropriate. Deficiencies are based on a violation of the statute or regulations, which, in turn, is to be based on observations of the OPT/OSP’s performance or practices. 

The Interpretive Guidelines include three parts:

• The first part contains the survey tag number. 
• The second part contains the wording of the regulation. 
• The third part contains guidance to surveyors, including additional survey procedures and probes.