I have a good friend that is the most organized, detailed guy that I know. He leaves no detail untouched and my other friends refer to his behavior as “stiff”.  He might own the original day planner and still uses the extra large version clad in in leather.  He is not the friend that you call and ask him to drop something at the moment and meet for lunch. In fact, my favorite quote from him is when he says he is very “spontaneous as long as it is well thought out and planned in advance”.  I was reminded by this quote when I looked at a lot of the drivel and conversations around RC 2-12 formerly RC 3 (for some background HERE).

The main driver of RC-3 was that APTA’s explicit position on who can provide physical therapy were antiquated, stifling, and unintentionally very damaging to the profession.  Opportunistically, medicare adopted the positions and thus you have reimbursed care being provided only by a PT or PTA  (ironically in medicare’s own language PTA’s are defined as non-clinicians).  Most insurance companies rightfully allow PT’s to direct and delegate within their scope of authority which is their state practice acts as opposed to APTA’s positions.  The private practice section, under strong leadership, challenged this in a few House of Delegate Sessions and eventually RC-3 was passed which states:

Resolved, That the American Physical Therapy Association (APTA) recognizes that physical therapy is provided by, or under the direction and supervision of, a physical therapist. Evaluation remains the complete responsibility of the physical therapist.

The position is a “permissive” versus the previous “prescriptive” position which wanted to defined explicitly what a PT can and can’t do, who they can and can’t supervise/delegate/direct and how they can and can’t do it.  Physician practice acts and positions are amongst the most permissive of any profession which has served them well.  There was one major caveat to the adoption of RC-3, at the House of Delegates in 2012, amended RC-3 to RC2-12 to make this position become effective upon implementation of necessary initiatives in education, practice, payment, regulation, and research and adoption of requisite APTA positions, standards, guidelines, policies, and procedures with an interim report to the House in 2013.  This process included exploring practice models due to the changing healthcare environment.  A reconstituted Task Force called HPPIDPT or the Health Professionals and Personnel Involved in the Delivery of Physical Therapy Task Force (admittedly, quite a mouthful) got to work on this House charge.  Full disclosure, I had the privilege of being on that task force with some incredible professionals which was about 3 years of work.  The produced product, which I believe is being furnished to delegates soon is an impressive one.  As best I can tell, outside of the clerical work of tossing out all of the old APTA positions and publishing the new one (admittedly a large amount of work but one that should not be used as an excuse to further delay), the position that physical therapy is by or under the supervision of a PT should be widely distributed and adopted. It is straightforward and has already been adopted by the House.

Unfortunately, there are rumblings of some components wanting to clarify or adopt models of care in conjunction with a permissive position.  Or worse, some want it replaced with RC 04-14 that is about a paragraph long and essentially goes backwards by equating the definition of physical therapy to the exclusive marriage of a PT and a PTA. The idea is that you can be permissive as long as you abide by models of care prescription (just like the spontaneous definition) or if it is only a PT or PTA.  There are also some older arguments that will resurface.  Here are a few:

1.  Some will read, “APTA recognizes that physical therapy is provided by, or under the direction and supervision of a physical therapist” and immediately interpret it as “APTA actively encourages PT’s to train, use, and promote techs as a cheap labor force and appropriate substitute.”  The message about PT’s education, judgment, and autonomy will get lost by the same folks that on the other side of their mouth will fight for PT’s to gain direct access.  A similar argument will be along the lines of, “APTAs policy will cause medicare to revalue the CPT codes cause they know PT’s will use techs”.  This recurrent theme of fear, slippery slope, and opening up debate of payment for techs is an emotional plea to say that PT’s don’t deserve to be a permissive profession.  Like physician practice acts, remaining silent on all of those areas is the only right way to proceed. If individual states (like NY) want to stifle their PT’s by their own practice acts, so be it but let’s not have our national association remain as the explicit arbitrator or example.  Lastly on this point, medicare is not the majority of patients seen in the outpatient setting and we certainly don’t need payers to follow their lead on superimposed rules.