What needs to be emphasized to CMS is that every licensed therapist is responsible for their student and we have documents and guidelines for different types of supervision.
Student services are provided under the therapist's professional license. No one wants to put their professional license at risk. That is how we ensure quality. Student skills and clinical decision making abilities are verified by the supervising therapist prior to progressing independence.
In the past we have received definitions and guidelines for different levels of supervision (direct, indirect, on site, line of sight).
I have a document titled "Chart: Supervision of Students Under Medicare" provided by the APTA and updated 9/5/14. The chart differentiates between Medicare Part A and B and the level of supervision required at different facilities. Is there now only 1 type of permissible supervision? (line of sight?)
SNF Y1 : recommendations state "Reimbursable: Therapy students are not required to be in line-of-sight of the professional supervising therapist/assistant (Federal Register, August 8, 2011).
SNF: PTA student: Y2 "Reimbursable : minutes of student services count on the minimal data set"
Hospital Y3 : Unspecified, use Y1 for guidance, and defer to state law and standards of professional practice
Acute Rehab: Y4: Unspecified, use Y1 for guidance, and defer to state law and standards of professional practice
Perhaps the same resources used to create this chart should be brought out and presented to CMS again?
Students "observe" and act as a "2nd pair of hands" PRIOR to therapy school as volunteers who are considering entering the profession. Preventing students from demonstrating that they can independently manage all aspects of patient care is not beneficial to the future of our profession or our patients.