American Speech-Language-Hearing Association
September 28, 2010

CMS Clarifies "Line of Sight" Supervision for Students in SNFs

The Minimum Data Set (MDS) 3.0, a tool used to assess Medicare beneficiaries in skilled nursing facilities (SNFs) will be implemented October 1, 2010. The MDS user manual, known as the Resident Assessment Instrument (RAI) manual, was also updated by CMS for October 1, 2010.

Currently, a therapy student who is participating in field experiences within a SNF, under Medicare Part A, must be under a "line of sight" level of supervision from the professional therapist. The RAI manual in chapter 3, section O was revised September 13, 2010, and clarifies this supervision requirement.

As of October 1, 2010, "line of sight" will mean "the supervising therapist/assistant shall not be treating or supervising other individuals and he/she is able to immediately intervene/assist the student as needed and the student and resident are both under line of sight supervision." We interpret this to mean that the supervising speech-language pathologist would be able to work on documentation while complying with the line of site requirements.

For further information, please contact Mark Kander at or Kate Romanow at

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