Declaratory Statements - PTA Roles

1. 01.11.02 Restorative care - I am a licensed P.T.A. working in the Baton Rouge area. Our facility has asked that I take over the restorative treatments since the restorative tech is no longer here. The PT. caseload is low and I donýt mind performing this task. However, restorative is a nursing concern and is specifically defined as NOT to be identified as therapy, so the pt and family are not confused. The current restorative patients have not been seen by P.T. except for the initial eval that states they are inappropriate for physical therapy at this time. Please clarify this issue for my facility. Can the PTA perform restorative duties within the facility and remain within practice guidelines? Currently, the supervising therapist is on site for 3-4 hours per day.

   A licensed physical therapist assistant may not perform restorative treatments under nursing services. A physical therapist assistant can only perform services under the direction of a licensed physical therapist. This may be in the form of treatment or, after a patient is discharged from skilled physical therapy, may be as preventative/wellness (pursuant to supervision requirements in Section 321 of Rules and Regulations).

2. Acute Care Hospital - 1) A patient was evaluated and a plan of care was established. The only activity performed was ROM exercise. The written goals were follow two step commands and increase ROM. Under plan part of eval was progressive mobilization and D/C planning. Can a PTA progressively mobilize (edge of bed, transfers, gait)? What can a PTA do? 2) Acute care hospital, PT evaluated (written treatment plan established). PT stood and oxygen saturations dropped, goal were standing tolerance 3 minutes and sit to stand with minimum assistance, plan is progress to gait as oxygen stabilizes and continue to mobilize daily, what can a PTA perform with this PT?

   1) Pursuant to Rule 323A (2), an initial physical therapy evaluation is the written document of patient history, pertinent medical diagnosis, signs, symptoms, objective tests or measurements, and the physical therapist's interpretation of such findings, as well as goals and treatment plan recommendations. In effect, the plan of care is written by the PT to identify the treatment interventions necessary to reach each goal.

   Once the physical therapy evaluation is properly written, the PTA may treat the patient within the current plan of care addressing established goals. When the patient has reached the established goals, the PT must reassess the patient and set new goals and advance the plan.

   It is the PTAs responsibility to communicate to the PT when the patient reaches the established goals, and needs reassessment and new goals setting. The PTA must also alert the PT if there is a decline in the patient's condition.

   In responding to the first scenario, if the plan established by the PT states "progressive mobilization," then the PTA may perform bed mobilization, transfers and gait. The term "progressive mobilization" is very broad. A more specific plan of care would be appropriate. It would be prudent and advisable for the PTA to ask the PT to be more specific in his written plan of care so as to avoid any unnecessary legal problems which may occur.

   2) In contrast to scenario 1 above, scenario 2 demonstrates a plan of care which is very clearly worded and the PTA may progress the patient's standing and walking tolerance with stable oxygen saturations as written by the PT in the plan of care.

3. Can a PTA perform standardized tests to improve balance? - Is a PTA allowed to perform, grade and document on standardized tests such as the Barg Balance, Romberg, Tinetti Balance & Gait and Dynamic Gait Index if improving balance is part of the plan of care?

   The board determined as long as the tests are initiated in the evaluation/plan of care by the physical therapist, then the physical therapist assistant can perform the test and report the results to the PT.

4. Cauterization using a Silver Nitrate Stick - Following the plan of care established by the supervising physical therapist, is it within the scope of practice for a PTA to perform cauterization using a silver nitrate stick??

   There are several pertinent parts of the practice act that have influenced the board's decision. I refer you to: Section 305. Special Definitions; Practice of Physical Therapy..Physical Therapy Supportive Personnel c. The level of responsibility assigned to the physical therapy supportive personnel is at the discretion of the physical therapist, who is ultimately responsible for the acts or omissions of these individuals. Supportive personnel may perform only those functions for which they have documented training and skills. The prohibitions for therapy supportive personnel shall include, but not be limited to, interpretation of referrals; performance of evaluations; initiation or adjustment of treatment programs; assumption of the responsibility of planning patient care; or any other matters as determined by the board. The physical therapist shall only delegate portions of the treatment sessions to an aide/technician only after the therapist has assessed the patient?s status. Also: Section 305 A. On Premises "means that the supervising Physical Therapist is personally present in the treating facility and immediately available to the treatment area." The Board's decision is that it is within the scope of practice for a PTA to apply the silver nitrate to a specific area of a wound only with the supervision of the physical therapist and after the physical therapist has evaluated the wound and made the determination of exactly where the agent should be used. Since the condition of a wound frequently changes from visit to visit this patient would require more frequent evaluations and reassessments. This means that the patient would have to be reassessed at every visit to determine if the patient's wound required continuation of the application of the silver nitrate and directing the application of the silver nitrate.

5. Clinical Instructor - Can a PTA serve as a clinical instructor and if so is a PT required to be on premises?

   The Board reviewed a letter requesting clarification of Physical Therapist Assistants' roles as Clinical Instructors. The Board respects the capabilities of Physical Therapist Assistants who are graduates of accredited programs and believe that they are or can be valuable clinical instructors for PTA students.

   The Board deliberated on the role that the student plays in the clinic. There are only three classifications of practitioners outlined in the Physical Therapy Practice Act: a licensed physical therapist, a licensed physical therapist assistant, and a physical therapy technician. Undercurrent law, the PTA student is not yet a graduate and not yet licensed; therefore, in the clinic must be considered a non-licensed worker. For the purpose of public protection, the Board feels that it must have students abide by the supervision requirements outlined for the technician. The Board is currently beginning the promulgation process of drafting rules and regulations regarding students which will in all probability change existing supervision requirements of those practitioners.

   Just as the Board cannot allow a Physical Therapist Assistant to supervise a technician providing patient care in the absence of the Physical Therapist, the Board cannot justify a PTA supervising a PTA student in the absence of the Physical Therapist. If you will note in Rules and Regulations, 321.B. Supervision Requirements of Physical Therapy Supportive Personnel by a Physical Therapist, a Physical Therapist Assistant permittee (a P.T.A. graduate who has not yet passed the licensing exam) must have continuous on premises supervision by a physical therapist.

   It is not logical that we should require less supervision for a non-graduate or student Physical Therapist Assistant.

   The law dictates that a physical therapist provide continuous on premises supervision of the Physical Therapy tech, P.T.A. permittee, and for the reasons stated above, the Physical Therapist Assistant student. This is not to say that a licensed P.T.A. cannot serve as a CI, but the Physical Therapist must be present and responsible.

   In order to provide exposure and experience in the home health, nursing home, or school system settings, the P.T. may serve as the clinical instructor or the licensed PTA may serve as the Cl with the P.T. providing continuous on premises supervision.

6. CMNs - May PTAs answer the questions on CMNs before they go to the physician for signing?

   You have submitted the CMNs which you said are typically used in the rehabilitation setting for wheelchairs, hospital beds and power chairs. When reviewing the CMNs, the board is of the opinion that it is the physical therapist's decision to determine the description of the equipment and to evaluate what equipment is needed. With regards to who fills out, or completes, the forms which you have submitted, the Board is of the opinion that it is not necessary for a physical therapist to perform such function. You may wish to verify that should a physical therapist not perform such function, is such protocol in compliance with HCFA guidelines.

7. Co-Signature of Student Notes. - Must PTA student notes be signed by a PT?

   Subpart 2. Practice Subchapter C. Supervised Practice 323. Documentation Standards

   D. Documentation by a student must be co-signed by a supervising physical therapist or supervising physical therapist assistant.

   A PTA student?s notes can be signed by the supervising PTA. It should also be noted that the supervising PT shall provide continuous, on premises supervision of a student in all practice settings. This means that even if a PTA is the supervisor, a PT must still provide continuous, on premises supervision.

8. HOME ASSESSMENT - Can a licensed PTA perform a home assessment? Can this be done in conjunction with an occupational therapist?

   Pursuant to the Physical Therapy Practice Act and the Rules and Regulations promulgated by the Board, it is not within the scope of practice for a PTA to perform a "home assessment". However, the PTA can collect data and measurement. For example, you can simply write down the measurement of door frames, rooms and home configuration, however, again you cannot interpret the data or make recommendations on home modification. This falls under the responsibility and scope of practice of the physical therapist. Additionally, such collection by the PTA cannot be done under the direction of or in conjunction with an occupational therapist. It is recommended that the term "collection" of data be used as opposed to "assessment" when the PTA collects data. In summary, it is the Board's position that it is beyond the scope of practice to do the assessment, interpret the data or make recommendations to the family on home modifications. To simply record information is not in and of itself a violation of the Physical Therapy Practice Act or the Rules and Regulations promulgated by the Board. However, to evaluate, assess and/or act upon such information is beyond the scope of the practice of the PTA.

9. Home Health - Question 1: I am a PTA that has recently started working for a home health agency. I am also the first PTA that has worked for them. A question has come up regarding a patient that has been hospitalized. Can a PTA see that patient first once the patient is out of the hospital, or does a PT need to be the first one to see the patient? Question 2: The orders were to resume PT. I could see if there were new orders then the PT would definitely have to see them. Is there a time frame for a hospitalized patient that warrants the PT to see them before the PTA can?

   Answer 1: It is the Board's opinion that pursuant to the Physical Therapy Practice Act and the Board's Rules, the physical therapist must see the patient first to determine whether or not the plan of care is appropriate. In other words, it is the physical therapist's obligation to re-assess the patient in order to determine if there is a change in the patient's status.

   Answer 2: Please refer to the Board's Response to Question 1 above. When a patient requires hospitalization, there has been a change in his status. The length of the hospital stay is not the issue. Any change in a patient's status requires a re-assessment by the physical therapist. In summary, the agency is correct in its interpretation of the physical therapist's obligation in your factual scenario.

10. Home Health 6th visit - Is a physical therapist assistant required to be present when a physical therapist does a reevaluation on the sixth visit for a home health patient?

    With regards to the State Minimal Standards, the Board does not require the presence of the physical therapist assistant, however, it is recommended that you consult with HCFA or other regulatory agencies with regards to such requirements. Additionally you may consult with your employer with regards to whether or not it has implemented this requirement Again, from a regulatory standpoint, the Board does not at this time require the physical therapist assistant to be present when a physical therapist does a reevaluation on the sixth visit for a home health patient.

11. Infrared (Anodyne) Treatment in Home Care - Can a Physical Therapy Assistant perform Infrared (Anodyne) treatments in the home care setting?

    In response to your question, the Louisiana Physical Therapy Practice Act LRS 37:2410 states:

    (5)(a) Physical therapist assistant means any person who is a graduate of an accredited school of physical therapy assisting, which school, at the time of graduation, was approved by the American Physical Therapy Association or the Louisiana State Board of Physical Therapy Examiners, and assists in the practice of physical therapy in accordance with the provisions of this Chapter, and who works under the supervision of a physical therapist by performing such patient-related activities assigned by a physical therapist which are commensurate with the physical therapist assistant?s education and training. (b) Physical therapist assistant means equally physical therapy assistant, physiotherapist assistant, and physiotherapy assistant, P.T.A. (c) A physical therapist assistant's work shall not include the interpretation and implementation of referrals or prescriptions, the performance of evaluations, or the determination or major modification of treatment programs.

    The treatment protocol for Infrared (Anodyne) treatments requires a Monofilament Sensory Test of the treatment area. The Physical Therapist Assistant may collect this data; however, the Physical Therapist must interpret the data.

    Please be advised that supervision requirements of PTA's by PT's are delineated in the Louisiana Physical Therapy Rules and Regulations in section 321. Supervision Requirements. The rule is listed below for your convenience.

    321. Supervision Requirements A. Licensed Physical Therapy Assistant 2. With regards to the requirement of periodic supervision of physical therapy services rendered by a licensed physical therapist assistant in nursing homes, school systems, and home health settings, the supervising therapist shall: a. be readily accessible be beeper or mobile phone; b. evaluate and establish a written treatment plan on the patient prior to implementation of any treatment program. c. treat and reassess the patient on at least every sixth visit but not less than once per month. d. conduct, once weekly, a face to face patient care conference with each physical therapist assistant to review progress and modification of treatment programs for all patients; and e. assess the final treatment rendered to the patient at discharge and write a discharge summary.

    The Physical Therapist is responsible for determining the delegation of treatment to the PTA.

    305 Special Definition: Practice of Physical Therapy A. As used in the definition of practice of physical therapy set forth in the Physical Therapy Practice Act, and used in this Chapter, the following terms shall have their meanings specified:

    Physical Therapy Supportive Personnel

    c. The level of responsibility assigned to physical therapy supportive personnel is at the discretion of the physical therapist, who is ultimately responsible for the acts or omissions of these individuals. Supportive personnel may perform only those functions for which they have documented training and skills. The prohibitions for physical therapy supportive personnel shall include, but not be limited to, interpretation of referrals; performance of evaluations; initiation or adjustment of treatment programs; assumption of the responsibility for planning patient care; or any other matters as determined by this board. The physical therapist shall only delegate portions of the treatment sessions to an aide/technician only after the therapist has assessed the patient's status.

12. In-service - Transfers to Techs - Will it be in violation of the Practice Act for a PTA to give an in-service on "Transfers" to a group of nurses and techs?

    The Board determined that this is not a violation of the practice act. The Physical Therapist Assistant by virtue of their didactic training and clinical responsibilities are well qualified to provide this training to nursing staff.

13. MD Office - We see Medicare, Worker's Comp, and standard insurances. Do the same supervision requirements of PTA's apply in this setting? (The physicians bill for therapy services.) More specifically, can a PT supervise a PTA directly 50% of the time worked and be available by cell and within 25 miles, as in outpatient PT? 1. Can a PTA work in the MD office and bill for PT services when PT is not present? 2. Can a PTA work in the MD office and bill for PT services if PT is present 50% of the time?

    First, in order for services to be identified and billed as physical therapy in any setting, including a physician's office, it must be provided by and under the supervision of a licensed physical therapist. In the case that you identify, it appears that the doctor's office would be classified as an outpatient setting for the purposes of supervision of a physical therapist assistant. The physical therapist must evaluate each patient and set up a written treatment plan prior to delegation of physical therapy treatment to a physical therapy assistant. The supervising physical therapist must be on premises daily at least of the physical therapy treatment hours in which the physical therapist assistant is rendering physical therapy treatment. When and if the physical therapist is out of the clinic, the supervising physical therapist must be accessible by beeper or mobile phone as well as present within a 25 mile radius of and 30 minutes or less travel time from the treating facility. The supervising physical therapist must treat and re-assess the patient at least every sixth visit. The supervising PT must also assess the final treatment to the patient at discharge and write the discharge summary. Supervision of a physical therapist assistant by a physician does not meet the supervision requirements as set forth in the Board?s Rules and Regulations and doing so may subject both the physical therapist and physical therapist assistant to discipliany.

14. MDS Form/SNF - Can a physical therapist assistant complete a MDS Form for a patient in a SNF Unit?

    The Board is of the opinion that a MDS Form is somewhat analogous to an evaluation in that both necessarily involve drawing conclusions with regards to the patient?s condition. Pursuant to the Physical Therapy Practice Act, LSA R.S. 37:2401 et seq., and the Board's Rules, a physical therapy evaluation can only be performed by a physical therapist licensed by the Board. Therefore, a physical therapist assistant, although licensed by the Board, does not have the qualifications or legal competency to certify or draw a conclusion in order to be in a position to complete a MDS Form. A physical therapist is responsible for completing this portion of a MDS form if the policy of the facility requires physical therapy to complete this portion.

15. Medicaid Skilled Patient in LTAC - What are the supervision requirements of a PTA when treating a Medicaid Skilled Patient in a long-term care facility? It has been Synergy's understanding that the level of nursing care for a Medicaid skilled patient continues to be at an ICF or part B level. This label of "Medicaid Skilled" is referring to a reimbursement view point. What role does a PTA have in the screening process? We understand that the PTA can not make the decision as to whether a screen is positive or negative, however, is the PTA able to obtain supporting information regarding a resident's needs, current/prior level of care, etc. and then present that information to the PT, who makes the decision as to whether a patient is appropriate for PT?

    The supervision requirements of a physical therapist assistant is governed by Rule 321 promulgated by the Board. If the facility is licensed as a SNF unit, then the requirements set forth in Subsection A1 of Rule 321 is applicable. In contrast, in the event the facility is licensed as a nursing home, then Subsection A2 of Rule 321 would apply. Therefore, for the Board to answer your particular question, it needs more information with regards to the licensing of the facility.

    A a physical therapist assistant can collect data and present such information to the physical therapist. However, it is the physical therapists obligation to perform the evaluation and make the appropriate plan of care.

16. Multidisciplinary team staffings. - Can a physical therapist assistant represent the patient in multidisciplinary team staffings?

    The Board is of the opinion that team staffing are used by facilities in order to establish the patient's plan of care. Since the physical therapist assistant is not allowed to establish or make changes to the plan of care, it is improper, and therefore a violation for the assistant to report in multidisciplinary staffing without the physical therapist present. Reporting patient changes and explaining their occurrence are more properly within the realm of training and experience of the physical therapist and, therefore, the licensed physical therapist is the proper entity to represent the patient's case during staffing.

17. Nutritional Component of Tissue Healing and Arthritis Treatment - Can a Physical Therapist Assistant recommend nutritional supplements if it is not in the MD's or PTs plan of care?

    It is not within the scope of practice of a physical therapist assistant to recommend nutritional supplements. It is suggested that you contact the State agency with the appropriate jurisdiction in this area.

18. Ordering Equipment, Home Exercise Program, CMNs - Question 1: May PTAs order equipment such as wheelchairs, walkers, AFOs for patients? If the patient?s equipments needs have been discussed in team conference in the presence of the physician and the primary therapist, and there is a physician?s prescription why would completion of the procedure to obtain equipment be out of their scope? Question 2: May PTAs answer the questions on CMNs before they go to the physician for signing? Question 3: May PTAs give patients that they have been working with a home exercise program?

    Answer 1: Yes, the PTA may order such equipment as referenced in your question based upon the factual scenario provided by your letter. Please be advised that it is the physical therapist?s responsibility o recommend what equipment is necessary and appropriate and to follow the physician?s prescription.

    Answer 2: In order for the Board to properly and completely respond to your question, please provide to my office a copy of the document what you are referring to.

    Answer 3: The Board is of the opinion that the PTA may give a patient who he has been working with a home exercise program; however, it is a violation of the Practice Act and the Board?s Rules for the PTA to establish such home exercise program.

19. Outpatient Clinic - Can a PTA treat patients in an out-patient clinic without written goals on an evaluation when the PT is not present?

    It is the Board's opinion that as required by the Physical Therapy Practice Act and the Board's Rules, an evaluation must contain written goals. See Rule 323A2 regarding the content and documentation requirements of an evaluation which a physical therapist must provide to be in compliance with the law. The Board's response regarding documentation applies in all practice settings. A physical therapist may not turn a patient over to a physical therapist assistant without prior establishment of a written treatment plan, including goals. Furthermore, the supervision requirements set forth in Rule 321 must be complied with. Also, pursuant to your legal and ethical obligations as a licensee, you are required to report any violation of the Physical Therapy Practice Act and/or Board Rules to the Board office. Therefore, if the scenario you referenced has occurred, please forward the particulars to the Board office as soon as possible for its review.

20. Rehab Manager - I would like to know if it is allowed by the board that a PTA is the Rehab Manager (head of PT & OT)?

    The board does not define manager in the Practice Act or in the Rules and Regulations as to who can or cannot be a manager in a Rehab Clinic. However, if the physical therapist assistant is treating, the supervision requirements by a physical therapist as outlined in the Rules and Regulations be fulfilled.

21. Restorative Program - Can a PTA establish a restorative program?

    The answer to your question is "no". A Restorative Program should properly function outside of the Physical Therapy Department and may be better administrated under the Nursing Department under the direction and supervision of a nurse. In this way, there is no confusion on the part of a patient, family or physician as to whether the patient is continuing Physical Therapy Services. The Physical Therapy staff may only assist in the training of personnel and may coordinate the referral from the patients to the Restorative Program. These individuals should not be identified as physical therapy technicians nor should the services be billed as Physical Therapy. The Restorative Program essentially functions to carry out a home exercise program as a caretaker would do in the patient's home setting.

22. Screening in Nursing Homes - Please provide clarification regarding screening Nursing Home patients and PTA supervision.

    The Board opinions that Nursing Home patient screens are to be performed by the physical therapist as per the Nursing Home policy. Usually the policy for performing screens is at least quarterly, on admit or if there is a history of falls or decline of function. Random screens are not acceptable because of privacy issues, and the HIPPA and Medicare guidelines.

    Given the PT/PTA clinical setting, no weekly face to face meeting is needed sine daily coordination and delegation of care occurs. At evaluation and before delegation of patient treatment to a PTA, the written treatment plan and goals must be specified for the PTA to follow. The PT performs at least every sixth visit (i.e. Complete treatment and reassessment) when a PTA has been delegated to treat a patient.

23. Sharp Debridement - Can a physical therapist assistant perform sharp debridement and what is his role in wound care?

    It is the Boards opinion that a physical therapist assistant cannot perform sharp debridement. The Board's decision is based upon the fact that during sharp debridement there is a need for constant evaluation and assessment of the tissue as the procedure is performed which requires the level of a physical therapist. Section 305 of the Board's Rules and Regulations provides as follows:

    The level of responsibility assigned to physical therapy supportive personnel is at the discretion of the physical therapist who is ultimately responsible for the acts or omissions of these individuals. Supportive personnel may perform only those functions for which they have documented training and skills. The prohibitions for physical therapy supportive personnel shall include, but not be limited to, interpretation of referrals, performance of evaluation procedures, initiation or adjustment of treatment programs, assumption of the responsibility for planning patient care, or any matters as determined by the Board. Sharp debridement involves two (2) levels of evaluation which are: a)assessment of wound status prior to each treatment and determination of appropriate debridement procedure required; and b)ongoing assessment as the procedure is actually being performed to determine viable versus nonviable tissue and when debridement is to be included.

    At present, there is a role for wound care for the physical therapist assistant. While it is not within the scope of practice for a physical therapist assistant to do sharp wound debridement with instrumentation such as the use of tweezers, scalpels, scissors or Norsen debriders, it is within the scope of practice for the physical therapist assistant to assist the therapist in wound care with dressing changes and in performing soft debridement of superficial necrotic tissue using techniques such as wiping with gauze or sponge and irrigation with pulsed lavage systems or bulb syringes.

24. Staple Extraction - What is the role of the PTA in staple extraction?

    The Board is of the opinion that a staple extractor is not considered a sharp debridement instrument and can be performed by a PTA if there is a physician's order and the PT has assessed the patient prior to use of the staple extractor. Additionally, the Board refers you to Rule 305 with regards to the level of responsibility which may be assigned to supportive personnel, including a PTA, by a PT.

25. Student Fundraising Activity - Question 1: Can PTA or PT student use massage skills in on-campus fundraising activities if the events were promoted as a learning experience, as well as a fundraiser? Question 2: If the Board considers ruling such an event on campus as appropriate, would the same type of event in another location, like the mail, fitness center, or sporting event, also be appropriate?

    In carefully considering this matter, the Board is of the opinion that such activities would not be a violation of the Physical Therapy Practice Act or the Board's Rules and Regulations if such activities were part of the educational process and supervised by the faculty. Additionally, the people receiving these services must be appropriately informed that such activities are part of the educational process and are being supervised by the faculty.

26. Supervision by MD - Does supervision have to be given by a physical therapist or can it be given by and MD?

    Only a licensed physical therapist can supervise a physical therapist assistant and/or a physical therapy technician pursuant to current Louisiana law.

27. Supervision - Can a licensed physical therapist assistant supervise a physical therapist assistant student when a licensed physical therapist is on premises in direct supervision?

    A licensed physical therapist assistant can be a clinical instructor for a physical therapist assistant student as long as a licensed physical therapist is on premises in direct supervision.

28. Supervision vs Billing - With regards to supervision of supportive personnel, more particularly a physical therapist assistant, what impact, if any, does billing have on the issue of supervision?

    At the outset, physical therapy services rendered by a physical therapist and/or physical therapist assistant are skilled services being rendered in any setting. With regards to whether a nursing facility is skilled or unskilled is determined by the state under rules and regulations applicable thereto. In summary, a physical therapist is a skilled provider. The supervision which a physical therapist provides to a physical therapist assistant depends on the type of facility which is determined by state and/or federal regulations and requirements. If the beds are licensed as skilled nursing beds, etc., then Rule and Regulation 32 1 (A)(1) is applicable. In the event the beds are not licensed as skilled nursing beds, then Rule & Regulation 321(A)(2) is applicable with regards to supervision of the physical therapist assistant. Therefore, the type of supervision required by Section 321 has nothing to do with the billing of physical therapy or what type of entity bills for such physical therapy.

29. Supine Manual Distraction of Spine - Can a PTA perform a supine manual traction?

    The Board is of the opinion that it is prohibited for a physical therapist assistant or any other supportive personnel to perform passive manipulation or mobilization of the spine. It is also the Board?s opinion that passive manipulation or mobilization of peripheral joints may be performed by licensed physical therapist assistants, but may not be delegated to any other supportive personnel.

    The PTA may perform massage and soft tissue treatment so long as the purpose is not to mobilize or treat the vertebral joints or facet joints.

30. Technician Assist Medicare Patient - I have heard that it is no longer permittable for technicians to assist with Medicare patients in an inpatient rehab setting. Is this correct? If so, could you send me/direct me to a specific site where I can locate this rule in writing for my administrative staff?

    The Board is aware that the environment of physical therapy services provided in the Medicare arena are evolving, however, the Board is not in the position to answer the specifics of the Medicare Rules and Regulations applicable to the inpatient rehab setting. It is recommended that you make inquiry of your Fiscal Intermediary for Medicare services.

31. Techs in Home Health -Safety Assistance - Can a PTA use a person in the home health setting to aid in pushing a wheelchair behind a patient while PTA is gait training the patient?

    This person is not treating the patient or assisting the PTA to treat the patient but rather there for safety reason to aid the PTA. The current Rules read that the PTA can be assisted to treat the patient as long as the PT is on the premises but in this scenario; but in this scenario, the person is not assisting the PTA in treatment of the patient and in the home health setting the PT is not always present.

    Your question references the use of a person, however; you did not define who this person is. In an attempt to answer your inquiry, please find a copy of a Declaratory Statement published in the Summer 1994 Newsletter with regards to physical therapy technicians/aides. The Board?s opinion set forth in the referenced Newsletter article is still valid.

    If in contrast, the person is a family member, visitor, or other healthcare professional, the Board is of the opinion that the physical therapist does not have to be personally present on the premises. However, please be advised that the physical therapist should asses the patient to verify that such activity is appropriate. Again, under no circumstances can the physical therapist assistant use a physical therapy technician/aide in your factual scenario without a physical therapist being on the premises. As a suggestion, in a situation where safety requires two physical therapy personnel, perhaps it is in the best interest of the patient for the physical therapist to personally attend to the patient with the assistance of the physical therapist assistant, technician/aide or other person present.

32. Traction set up - Can a PTA perform CPM or Buck's Tractin set ups on a patient without the physical therapist involvement?

    The Board refers you to LRS 37:2410 - 37:2421 Section 321. Supervision Requirements of the Rules and Regulations. A physical therapist must first evaluate and provide a written treatment plan before any procedures can be delegated to a physical therapist assistant.

33. Wound care performed by PTA - Question 1: Can a PTA, who is properly trained, perform wound care on a patient when the wound care physician, a surgeon, writes an order for wound care, not an order for PT? Can the PTA carry out the treatment, without the supervision of a PT? The wound care physician would direct the wound care by visiting the patient and collaborating with the PTA, weekly. The treatment rendered is not billed as PT, nor referred to as PT under any circumstances. Should his signature not include the PTA suffix? Question 2: If the answer to question 1 is yes, he can work without the supervision of a PT, would that wound care person, who happens to be a PTA, be able to do sharp debridement, under the direction of the Wound Care (surgeon) Physician? Question 3: If the answer to question 1 is no, would it matter if the PTA becomes wound care certified? Would this allow him to work independently from the supervision of a PT, and allow him to do sharp debridement?

    A Physical Therapy Assistant must always work under the supervision of a Physical Therapist. A PTA is always a PTA and that does not change regardless of the involvement of the Physician or billing as a Physical Therapy service. If a person is licensed as a PTA and working in the healthcare arena, in any position, they will be held to the Physical Therapy Practice Act and the Rules and Regulations that govern that Act. Furthermore, it is not within the scope of practice for PTAýs to do sharps debridement in the state of Louisiana. This is a procedure that requires constant evaluation of the tissue involved. Additionally, certification in wound care would not change the supervision and scope of practice issues relating to a PTA. As indicated in Section 305 of the Louisiana Physical Therapy Rules and Regulations:

    305. Special Definition: Practice of Physical Therapy A. As used in the definition of practice of physical therapy set forth in the Physical Therapy Practice Act, and as used in this Chapter, the following terms shall have their meanings specified: . . Wound Care and Debridement - a physical therapist, physical therapist permittee or student physical therapist may perform wound debridement and wound management that includes, but is not limited to, sharps debridement, debridement with other agents, dry dressings, wet dressings, topical agents including enzymes, and hydrotherapy. A physical therapist assistant, physical therapist assistant permittee or student physical therapist assistant shall not perform sharps debridement. The boardýs licensees and permittees, as well as students and supportive personnel, shall comply with the supervision requirements set forth in 321.

34. DHH one year experience - Can a PTA who recently obtained q license in Sept.2007 practice in the Early Steps program under current supervision guidelines without having a year experience?

    According to rules established by the Department of Health and Hospitals (DHH), a PTA must have one year experience prior to working in home health or school settings. This rule coincides with the current requirement established by DHH.

35. Can a PTA conduct a work screen? - I work at a hospital based outpatient clinic. The physical therapy department is responsible for completing the pre-work screens for all new hires for the hospital. These screens involve collecting/documenting a variety of data for the Employee Health department. Data collected includes (but is not limited to): blood pressure, heart rate, gross ROM measurements, presence of crepitus at the knee, etc. Body mechanics of various work related tasks (overhead work, push/pull, lifting) are also rated (good/fair/poor). We do not make a final judgment of whether a candidate passes or fails the test; we only state that the candidate has met or has not met the criteria. We have reviewed similar questions on the boardýs website and feel that there is a grey area open to interpretation involving a PTAýs involvement in screens. We would like to clarify with the board regarding our specific situation. Our question to the board is 1) Can a PTA complete these work screens independently of a PT since there is not formal assessment of pass/fail on our specific screens and essentially only data collection is being completed? 2) If a PTA can complete the screen, does the paperwork require a co-signature by a PT? 3) If a PTA can complete the screen and does not require a co-signature, does there have to be on-site supervision of the PTA by a PT?

    The board determined it is not within the physical therapist assistants scope of practice to conduct these work screens.

36. 04.10.03 OASIS and the PT/PTA - Petition: I am an RN for a home care agency in Louisiana. I am responsible for Performance Improvement and Education. I will be conducting an inservice to a group of PT and PTAs pertaining to home care admits and answering the Oasis question appropriately. My question is to what extent do therapists perform clinical evaluations on a patient in the home care setting. 1) Do therapists receive treating in vital signs? 2) Are therapist trained I assessing breath sounds, heart sounds or bowel sounds? 3) Do therapists receive education pertaining to medicationsýi.e. trade vs. generic names, contraindications, etc.

    First PTAs may not perform any of the OASIS admits, assessments, recertification's, or discharges.

    Secondly, Physical Therapists are trained and able to perform vital signs. PTs or PTAs are not trained to make decisions regarding drug interactions, trade vs. generic knowledge or dosage issues.

    Thirdly, if an agency trains and documents competence in assessing bowel sounds, heart sounds and breath sounds by a physical therapist, this is allowed per agency policy and procedure. Since OASIS assessments are designed for RNs, care must be taken to insure training and competence of the physical therapist to perform these tasks. Physical Therapists receive basic pharmacology training in school but not at a sufficient level to be trained to perform an OASIS medication assessment.