CMS Reaffirms Student Participation in Hospitals and IRFs

December 20, 2018

On Thursday, December 20, 2018, the Centers for Medicare & Medicaid Services (CMS) officially responded to requests from ASHA, the American Occupational Therapy Association (AOTA), and the American Physical Therapy Association (APTA) regarding student supervision in acute care hospitals and inpatient rehabilitation facilities (IRFs). The response followed a recent meeting with Medicare representatives and correspondence sent jointly by ASHA, AOTA, and APTA. 

CMS confirmed that there has been no policy change on the use of students, and expressed their recognition of the value and continued support of clinical education for students across health care settings including acute care hospitals and IRFs.

CMS provided the following statements in their official response [PDF]:

  • “…CMS has not changed its policy with regard to the CoPs [Conditions of Participation] and the provision of healthcare services by students in hospitals, including therapy students providing rehabilitative services in hospitals and IRFs.
  • “…no requirements or interpretive guidance exist that prohibit students (including, but not limited to, therapy students, medical students, nursing students, and other allied health students) from providing patient care services as part of their respective training programs.”
  • “…CMS expects that all student therapy services will be provided by students under the supervision of a licensed therapist allowed by the hospital to provide such services.”

ASHA appreciates the clarification provided by CMS that reaffirms the ability of students to receive clinical education and provide services in hospitals and IRFs.


Recent confusion related to the use of students in hospitals and inpatient rehabilitation facilities developed as a result of questions asked during an educational call with CMS officials. ASHA staff responded immediately by contacting CMS regarding the issue and requested a public response to assure students as well as staff in academic programs and clinical facilities, that CMS had not changed any policies related to students’ delivery of services in acute and post-acute settings with appropriate supervision. 


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ASHA Corporate Partners