Therapy students and Medicare: what CMS says for Part B and for SNF Part A
CMS publishes different student rules for different Medicare settings, and this page keeps them apart. For Part B outpatient therapy, CMS’s Benefit Policy Manual says only the therapist’s services can be billed, and students’ services are not paid even under line-of-sight supervision. The qualified practitioner must be in the room for the whole session, directing the service. For skilled nursing facility residents under Part A, CMS’s MDS 3.0 RAI Manual says therapy students do not need to be in line of sight of the supervising therapist or assistant, and each facility’s supervising staff decide when a student is ready. Both sources cover physical therapy, occupational therapy, and speech-language pathology.
Quoted from official pages checked November 10, 2026. Confirm current requirements, fees, and dates on those sites. This page is not legal advice and does not guarantee eligibility, certification, or licensure.
Two CMS sources were read on November 10, 2026: the Medicare Benefit Policy Manual, Chapter 15, section 230 (Practice of Physical Therapy, Occupational Therapy, and Speech-Language Pathology; Rev. 63), and the MDS 3.0 RAI User’s Manual, version 1.20.11 (October 2026, effective October 1, 2026), Chapter 3, Section O, posted on CMS’s RAI Manual page. They are quoted separately and are not reconciled.
Part B outpatient therapy: the Benefit Policy Manual
Section 230 B, “Therapy Students”, states: “Only the services of the therapist can be billed and paid under Medicare Part B. The services performed by a student are not reimbursed even if provided under ‘line of sight’ supervision of the therapist; however, the presence of the student ‘in the room’ does not make the service unbillable.” It states that therapists may bill and be paid in these scenarios:
- “The qualified practitioner is present and in the room for the entire session. The student participates in the delivery of services when the qualified practitioner is directing the service, making the skilled judgment, and is responsible for the assessment and treatment.”
- “The qualified practitioner is present in the room guiding the student in service delivery when the therapy student and the therapy assistant student are participating in the provision of services, and the practitioner is not engaged in treating another patient or doing other tasks at the same time.”
- “The qualified practitioner is responsible for the services and as such, signs all documentation. (A student may, of course, also sign but it is not necessary since the Part B payment is for the clinician’s service, not for the student’s services).”
On group therapy, it states: “Group therapy services performed by a therapist or physician may be billed when a student is also present ‘in the room’.” On assistants as instructors: “Physical therapist assistants and occupational therapy assistants are not precluded from serving as clinical instructors for therapy students, while providing services within their scope of work and performed under the direction and supervision of a licensed physical or occupational therapist to a Medicare beneficiary.” It also states: “The payment methodologies for Part A and B therapy services rendered by a student are different.” And: “Students do not meet the definition of practitioners under Medicare Part B.”
SNF residents: the MDS 3.0 RAI Manual
Section O’s “Therapy Students” text states: “Medicare Part A—Therapy students are not required to be in the line of sight of the professional supervising therapist/assistant (Federal Register, August 8, 2011).” It continues: “Within individual facilities, supervising therapists/assistants must make the determination as to whether or not a student is ready to treat patients without line-of-sight supervision. Additionally, all state and professional practice guidelines for student supervision must be followed.” And: “All time that the student spends with patients should be documented.”
For Part B services in a long-term care facility, the RAI Manual lists criteria including: “The qualified professional is present and in the room for the entire session.” and “The practitioner is not engaged in treating another patient or doing other tasks at the same time.” Its assistant line reads: “Physical therapy assistants and occupational therapy assistants are not precluded from serving as clinical instructors for therapy assistant students while providing services within their scope of work and performed under the direction and supervision of a qualified physical or occupational therapist.” That wording says “therapy assistant students”, while the Benefit Policy Manual says “therapy students”. This page does not decide which applies.
The RAI Manual’s therapy items include “Speech-Language Pathology and Audiology Services” along with occupational and physical therapy. Its rules on coding student minutes go beyond what is quoted here; read Section O itself.
What these rules are, and are not
Both are Medicare payment and assessment rules. They are not school, accreditor, or state-board rules for supervising students. ACOTE, CAPTE, and ASHA requirements for fieldwork educators and clinical instructors are on becoming a clinical instructor, and what students do in clinical education is on fieldwork and clinical education. State practice acts and payers other than Medicare may set different rules.
What this page does not do
It gives no supervision ratios, minute counts, or payment amounts beyond the CMS wording quoted above. It is not legal, billing, or compliance advice. Confirm current rules with the agency that publishes them, your employer, and your state board.