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ASHA to Meet with CMS on Student Supervision Rules in IRFs

November 16, 2018

During a Medicare Learning Network event titled, Inpatient Rehab Facilities (IRF) Payment and Coverage Policies: FY 2019 Final Rule, hosted by the Centers for Medicare & Medicaid Services (CMS) on Thursday, November 15, a number of questions were posed to CMS officials about whether student services can count towards the 3-hour rule/intensity of therapy services requirement in the IRF setting. CMS clarified that students are not qualified providers of skilled rehabilitation services; however, CMS did not offer additional details on student supervision requirements that allow students to participate in clinical education and training.

The American Occupational Therapy Association (AOTA), American Physical Therapy Association (APTA), and ASHA have requested an in-person meeting with CMS officials to discuss this issue in more detail. To ensure the continued development of a highly trained and well-qualified therapy workforce, AOTA, APTA, and ASHA strongly believe CMS must collaborate with therapy stakeholders to develop guidance that allows therapy students to receive the quality clinical training and experience they require while also maintaining patient quality standards and ensuring the integrity of the Medicare program. The therapy organizations will provide additional guidance as soon as it becomes available. Additional information will be shared as developments warrant.

ASHA will provide our members with updates on the student supervision requirements through ASHA Headlines and ASHA's Advocacy website.


For questions, please contact ASHA's health care and education policy team at

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