How To Provide Physical Therapy As An Ancillary Service

By Jonathan Moore, DPM

      It should not be news that adding ancillary services to your practice not only improves patient outcomes (if done right) but moreover, ancillary services have the ability to improve your bottom line dramatically. Some estimates state upward of a 60 percent boost or higher to the bottom line. While podiatry has long been familiar with ancillary services like X-ray, vascular testing, nerve conduction testing and ultrasound, physical therapy (PT) has for many years been left off the table.       Why is this? For the most part, it probably comes from confusion over Stark Law, and even more confusion and fear over how to do it. Before we get into the “why” and “how,” let us make sure we have an understanding as to what we are not talking about in our discussion of in-office physical therapy.       For many years (and probably currently), podiatrists would randomly employ the use of ultrasound on a patient after an injection or the use of a whirlpool for a patient with a sprained ankle. In fact, many DPMs would have a nurse provide these services after they left the room while subsequently billing the physical therapy codes for this service.       Under current CMS rules, two components must be in place in order for one to bill for physical therapy services of any kind in the office setting without a physical therapist.       One must have a plan of care in place that specifies short- and long-term goals, objectives and specific modalities appropriate for the condition. In addition, services under this plan of care must be provided by someone formally trained in physical or occupational therapy.       Random whirlpool sessions or ultrasound treatments without a specific physical therapy plan of care in the chart is not only inappropriate as an “incident to” service, it is really not something that improves patient outcomes in the long run.       While it is appropriate for podiatric physicians to provide and bill for physical therapy services themselves, it would be difficult to make this economically feasible in most podiatric offices.       Every state has its own rules and guidelines (local carrier decisions) that pertain to physical and occupational therapy. Some states, in fact, have made physician-owned physical therapy illegal by circumventing Stark and employing rules that make it impossible for a physical therapist to take orders from a physician employer.       Furthermore, the model that is presented below is one model. While there are other legal models for integrating physical therapy, the model below is one that I have found to be the most practical for the podiatry office. Consult your local healthcare attorney to decide what model is best for you.


There is definitely a growing need for PT and it's no surprise that physical therapy jobs are in high demand. Training staff properly is a must for fulfilling the needs of patients.

Add new comment