Free consultation calls in a therapy practice

Occupational therapy, physical therapy and speech-language pathology practices serving children, adults or both should fix a free consultation call’s purpose before offering it: an administrative or educational conversation about fit, fees and next steps, not an evaluation, described the same way in every invitation, script and listing.

What is a free consultation call in a therapy practice?

It is a short conversation at no charge before any evaluation, and its meaning depends on the purpose the practice gives it. The phrase covers three things: an administrative call about fit, fees and scheduling; an educational call about what the discipline does and how the evaluation works; and a clinical call in which a therapist hears one person’s concern and responds to it. The first two can be offered free with clear limits. The third is clinical work whatever it is called, with the documentation, licensure, payer and consent questions that come with it.

Most confusion comes from offering the third while advertising the first: a parent may expect to hear whether a child needs therapy, an adult a few exercises. Decide which call you offer, then build the invitation, script and record around it.

The intake call script covers the first column. This guide covers the second, and the line between it and the third.

Why can the word consultation mislead a caller?

Because it sounds like an expert opinion about the caller’s own situation. The Federation of State Boards of Physical Therapy’s Model Practice Act, a model that state laws may differ from, defines “consultation” as a physical therapist seeking or giving professional or expert opinion or advice to another PT or health care provider.⁠⁵ ASHA’s code requires members to represent the intended purpose of a service accurately, and APTA’s code requires truthful, accurate information about services.⁠^1,2

A name that says what the call does sets expectations before it starts: a free questions call, a free call to see whether we are the right fit, a free introduction to our feeding program. Use the same name on the website, the voicemail greeting, directory listings and the booking confirmation.

Should a therapy practice offer free consultation calls at all?

Offer one when it answers a question the intake call cannot, and skip it when it only moves the evaluation’s work into unpaid time. It earns its place when:

• The caller does not know which discipline to ask for. A parent unsure whether a late talker needs speech therapy or OT, or an adult after a stroke unsure whether PT, OT or speech therapy comes first, learns what each service does and which evaluation to book.
• The practice is self-pay or out of network. Callers paying the full fee often want to hear who they would see and what the evaluation includes before committing.
• Fit depends on setting, equipment or schedule. A feeding program, home visits or a group can carry conditions best explained by the person who runs them.

It costs more than it returns when the intake call already answers fit, fees and next steps, when clinician hours are scarce and the waitlist long, or when callers expect advice and the call becomes an unbilled assessment. Decide with the measures below, not by habit.

Which decisions should a practice settle before offering free calls?

Five, in writing before the first invitation goes out, because each shapes the script, the advertisement and the record:

Keep the result as a one-page policy with an owner, so the website, the front desk and the clinicians describe the same call.

What can a therapist say on a free call without evaluating?

General information about the service, the practice and the process, but not a diagnosis, a judgment about this person’s condition, or advice for this person’s care. The line sits where describing what the practice does turns into deciding something about the caller.

Each code draws the line in its own words. APTA’s Code of Ethics, dated January 1, 2026, makes the physical therapist fully responsible for all aspects of the evaluation and management of the patient, and bars exceeding professional, jurisdictional and personal scopes of practice.⁠^1,15 ASHA’s 2023 Code of Ethics allows a reasonable statement of prognosis but bars promising treatment results directly or by implication, and bars clinical services provided solely by written communication, which matters when a free consultation runs by email or chat.⁠² AOTA’s 2025 Occupational Therapy Code of Ethics rests on core values and guiding principles, veracity among them, with separate enforceable Standards of Conduct that OTs should read in the code itself.⁠^3,4

State practice acts define what counts as practice, and no single state’s wording describes them all. In the FSBPT model act, the PT and patient relationship can be formal or inferred, and begins once the PT assumes or undertakes care or treatment.⁠⁵ OT practice is regulated by state licensure agencies, and ASHA notes that state statutes and regulations take precedence over its guidance.⁠^16,17

What should a clinician say when a caller asks for a diagnosis?

Say plainly that the call cannot answer it, say why, and offer the route that can. Callers ask “Is this autism?” or “Is my knee torn?” because they are worried, and a guess on a free call, reassuring or alarming, is the answer most likely to mislead.

If anything the caller says sounds urgent, the call stops being a consultation: follow the practice’s urgent-call procedure, as the intake call script sets out.

Who on the team should take a free consultation call?

Whoever can do what the call promises without going past it: trained intake staff for an administrative call, a clinician for an educational call about a discipline. APTA’s code requires duties a PT directs to others to match their credentials and legal scope, and ASHA’s code bars delegating tasks that need an SLP’s unique skills or judgment to nonprofessionals; ASHA also requires telling people the name, role and credentials of whoever provides services.⁠^1,2 So the person on the call says who they are and whether they are a licensed therapist, and staff have the redirect wording and a clinician to hand questions to.

How should free calls differ for children’s families and adults?

The boundary is the same; the caller, the questions and the people on the line differ, so a practice seeing both ages writes two versions of its outline.

Calls about a child come from a parent or caregiver, usually with the child elsewhere. The questions run to development, school and timing; answer the service and process questions and keep developmental judgments for the evaluation. Record who the caller is to the child, since separated parents may each call. The IEP team guide covers how private therapy differs from school services, and the infant development guide covers the youngest children. For a teenager, decide whether the teen joins.

Calls about an adult come from the adult or from someone helping: a spouse, a grown son or daughter, a friend. When the adult is on the call and able to decide, HIPAA lets a covered practice share with a helper the information directly relevant to that person’s involvement once the adult agrees, or is given the chance to object and does not.⁠¹⁸ Ask the adult directly rather than relying on the helper’s account; an adult with aphasia or dysarthria may prefer a slower call, relay or a written route.

Does a free call with an out-of-state caller raise licensure issues?

It can, once anything clinical is said, because licensure follows the patient. HHS states that health professionals must meet the licensure requirements of the state where they are located and be licensed or legally permitted to practice in the state where the patient is located.⁠⁶ ASHA tells clinicians to verify requirements in both states before initiating services, and AOTA describes an OT license as the privilege to practice in the state that issued it.⁠^16,17

HHS advises verifying patient location before an appointment, notes that cross-state practice varies by state regulation, and describes multi-state licensure compacts that let participating providers practice in participating states.⁠⁷ Ask where the caller is at the start of every free call; with a caller in a state where the clinician holds no license or compact privilege, keep the call administrative and educational, and if coming to the practice is not realistic, help the caller find a clinic in their own state.

When does HIPAA apply to a free consultation call?

When the practice is a HIPAA covered entity: a provider is covered only if it sends health information electronically as part of a transaction HHS has set a standard for.⁠^8,19 A practice outside that definition falls outside the HIPAA Rules, though professional confidentiality duties, such as those in APTA’s and ASHA’s codes, still apply.⁠^1,2,19

In a covered practice, what a caller says is health information whether spoken or written: the rule covers information, oral or recorded in any form, that relates to a person’s health or health care, identifiable health information includes demographic details collected from the person, and protected health information covers any form or medium, paper included.⁠⁸ Notes the practice uses to make decisions about the caller, such as whether to book them, can fall within the designated record set, which includes records used in whole or in part to make decisions about individuals.⁠⁹

So keep free-call notes in the practice’s protected system with the inquiry, not in a notebook, a personal phone or a marketing tool; when a video or phone vendor acts as a business associate, have the written business associate contract HHS requires; and write down only what the next step needs.⁠¹⁹

What may a follow-up voicemail or email after a free call say?

Very little about health. HHS advises limiting an answering-machine message, for example to the practice’s name and number or a request to call back.⁠²⁰ Email is permitted with reasonable safeguards, one HHS example being to check the address before sending, and a provider can assume email suits a patient who writes first unless told otherwise.⁠²¹ The reply standards guide has the wording, and the appointment reminders guide covers texts once an evaluation is booked.

Can a practice offer free calls to Medicare or Medicaid patients?

It depends on what the call is, and the answer belongs to the practice’s counsel; OIG’s guidance frames the question. The Beneficiary Inducements civil monetary penalty applies to anyone who offers or transfers remuneration to a Medicare or State health care program beneficiary that they know or should know is likely to influence the beneficiary’s selection of a provider.⁠²² Remuneration includes transfers of items or services for free or for other than fair market value.⁠^10,11

Two limits shape the analysis. OIG interprets nominal value as a retail value of no more than $15 per item or $75 a year in total per patient, never cash or cash equivalents; a gift within those amounts need not fit an exception.⁠¹⁰ The regulation also excludes items or services that improve a beneficiary’s ability to obtain Medicare or Medicaid items and services and pose a low risk of harm: unlikely to skew clinical decision making, unlikely to increase costs through overutilization, and not raising safety or quality concerns.⁠¹¹ The Federal anti-kickback statute is separate, an intent-based criminal statute about exchanging anything of value for federal health care program referrals.⁠²²

An informational call every inquirer receives on the same terms, whatever their coverage, is a different arrangement from free clinical work offered to attract Medicare or Medicaid patients, such as a free screening. Neither is automatically barred or automatically safe. Take the second kind, and any free call bundled with a gift, to counsel before advertising it, with what the call contains, who receives it, how it is promoted and what it would cost to buy.

What does the FTC expect when an ad offers a free consultation?

That the ad is truthful, that every condition on the free offer is stated clearly at the outset, and that the free part is not recovered by raising another price. The FTC’s small-business guidance states that advertising must be truthful and non-deceptive, that advertisers must have evidence to back up their claims, and that the FTC looks at what an ad leaves out.⁠¹²

The FTC’s guide on the word “free” covers free merchandise and services and asks for extreme care. Every term, condition and obligation should appear clearly and conspicuously at the outset, not in a footnote reached by an asterisk; with a purchase, “free” means paying no more than the regular price for the item bought; and renaming a deceptive offer a “gift” or “bonus” does not cure it.⁠¹³ The professional codes agree: APTA requires truthful, accurate information about services, and ASHA bars misrepresentation when promoting services.⁠^1,2

State the length, who takes it, that it is not an evaluation, and who may book it, and leave outcome claims out: “find out if your child needs therapy” promises a judgment the call cannot give. Use one statement on the website, the directory profile and the confirmation.

What should a free call tell a self-pay caller about cost?

The evaluation’s fee and the fact that a written good faith estimate is available, because a cost question from an uninsured or self-pay caller is a request for one. The rule covers people without benefits for the service and people with coverage who do not want a claim submitted. It requires the provider to find out whether a caller is one of them, to tell them orally that an estimate is available when cost questions come up, and to count any conversation or question about potential costs as a request, with the written estimate due no later than 3 business days after it.⁠¹⁴

So whoever takes free calls asks whether the caller plans to use insurance, logs the date of any cost question as the request date, and passes it to whoever issues estimates. The scheduling deadlines and the estimate’s contents are in the guide to callers who do not book; the payment guide has wording for insured callers.

Mark where free ends. If anything offered after the call has a fee, such as a paid parent session, say so before it starts: APTA’s code requires PTs to inform patients of their financial obligations before charges are incurred.⁠¹

Does a caller need a referral before a free call or an evaluation?

Not for a free call the practice does not bill; for the evaluation, it depends on the discipline, the state and the payer, and the free call is a good place to say which applies.

Write the answers for your state and main plans on one dated page beside the phone, and end the free call with any document the caller needs and who requests it. Working with the offices that write those documents is covered in the pediatrician referral guide and the adult referral guide.

How do you make a free consultation call accessible to every caller?

Offer it in forms every caller can use: relay, an interpreter, captioned video or a written route. Under title III of the ADA, businesses and nonprofit organizations open to the public must communicate effectively with people who have communication disabilities, and the rules reach a patient’s parent, spouse or companion in appropriate circumstances; staff must answer relay calls the way they answer any other call, and no one can be required to bring their own interpreter.⁠²⁶

Relay, in the FCC’s description, lets people with hearing or speech disabilities make and take phone calls; dialing 711 reaches certain forms of it, and Speech-to-Speech relay is the form used by a person with a speech disability, such as an adult with dysarthria after a stroke. The FCC also warns that some people hang up on relay calls, mistaking the operator for a telemarketer.⁠²⁷ APTA’s code also asks PTs to address barriers to communication with patients and caregivers.⁠¹

Language access has its own rule. Under Section 1557, a covered entity, a category that includes recipients of federal financial assistance, must take reasonable steps to give each person with limited English proficiency meaningful access: the help must be free, accurate and timely, a qualified interpreter must be offered when interpretation is required, and no caller may be made to supply or pay for their own.⁠^28,29 Whether the rule reaches your practice is a question for your compliance adviser; where it does, book the interpreter with the call. The accessible inquiry forms guide and bilingual services guide cover written routes and a second-language service.

How should a free consultation call be structured?

Open with what the call is and is not, spend most of it on the caller’s questions, and end with one next step and a record of what was agreed.

1. Confirm the basics. Who is calling, for whom, from which state, and how to reach them.
2. Say what the call is. Read the opening statement.
3. Hear the question. In the caller’s words, noted without labeling it.
4. Answer what the call can. Fit, the evaluation, the fee or payer steps, referral, access.
5. Name what needs an evaluation. Use the redirect wording.
6. Agree one next step. An evaluation, an estimate, a referral request, the waitlist, another clinic, or nothing.
7. Read it back and record it. Who acts, by when, and the caller’s contact choice.

What should the record of a free call include?

The terms as agreed, the questions asked, what was answered and the next step, in the inquiry record of the practice’s protected system, written before the call ends.

Leave clinical impressions out: if the clinician formed one, the call went past its purpose, and that judgment belongs in the evaluation. The email templates cover the written follow-up.

How can a practice tell whether free calls are worth the time?

Count what the calls produce in your own practice for a quarter, and set it beside what the same clinician hours would otherwise do; no published rate answers that for your discipline, payers and callers.

Then compare the kept rate of evaluations booked after a free call with those booked from the intake call alone, by discipline; price the clinician minutes at what an evaluation hour brings in; and read the repeated questions, which a clearer service page or listing may answer without a call. A caller sent to a better-suited clinic counts as a useful call. With few calls a quarter, read two quarters together and compare with your own history, not another practice’s.

How might a free call go when a caller wants a diagnosis?

By holding the boundary kindly and turning the question into an evaluation or an honest referral, as in this hypothetical.

Where do DrSensory inquiries fit with free consultation calls?

A family that finds the clinic on DrSensory can write to it from the clinic’s profile, and the clinic’s reply is a natural place to offer its free call. DrSensory is a free directory for families looking for occupational, physical and speech therapy clinics that see children and adults, across all 50 states and Washington, DC; it lists clinics rather than individual therapists, one listing per practice at one address, and each clinic has a free basic listing.

A paid listing adds a description in the clinic’s own words, a logo, up to five photos, hours, specialties, ages and conditions treated, the website link, reviews with public replies, and family inquiries that come to the clinic. Then, when a family writes, the clinic’s inquiry address gets a notice, the message itself is opened in the DrSensory portal, and the reply goes out from the clinic’s own email, under the same rules as any inquiry. Describe any free call in the listing in the website’s words, and keep the listed ages and services matched to what the call can book. The profile guide covers the fields, and the pricing page compares the free and paid listings.

Sources

1. American Physical Therapy Association. APTA Code of Ethics for the Physical Therapy Profession (the code for physical therapists and physical therapist assistants, PDF; Standards of Conduct 1.2, 2.1, 3.1, 5.2, 6.1, 6.6, 7.1 and 8.1). Checked October 24, 2026.
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   “Physical therapists and physical therapist assistants shall protect patients’ and clients’ confidential information and not disclose that confidential information except as authorized by the patient or client or as permitted or required by law.”; “The physical therapist shall retain full responsibility for all physical therapist services provided under the provisions of the physical therapist’s license, including all aspects of the evaluation and management of the patient or client.”; “shall not exceed their professional, jurisdictional, and personal scopes of practice and shall communicate with, collaborate with, or refer to a peer or other health care professionals when necessary”; “shall address barriers to communication and comprehension with recipients of services, caregivers, students, and research participants”; “shall provide information about their services that is truthful and accurate and shall not make misleading representations in any forms of communication, including billing”; “Physical therapists shall ensure that patients and clients are informed of their financial obligations prior to incurring charges”; “Physical therapists shall ensure that all duties directed to other physical therapy personnel are congruent with the credentials, qualifications, competencies, and legal scope of practice or scope of work of the individual.”; “refer a patient or client to another health care professional when it is in the best interests of the patient or client”.
2. American Speech-Language-Hearing Association. Code of Ethics (ASHA policy document, 2023; Principles of Ethics I, II and III). Checked October 24, 2026.
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   “Effective March 1, 2023.”; “Individuals shall use every resource, including referral and/or interprofessional collaboration when appropriate, to ensure that quality service is provided.”; “they shall inform those they serve professionally of the name, role, and professional credentials of persons providing services”; “shall not delegate tasks that require the unique skills, knowledge, judgment, or credentials that are within the scope of their profession to aides, assistants, technicians, or any nonprofessionals over whom they have supervisory responsibility.”; “Individuals shall accurately represent the intended purpose of a service, product, or research endeavor”; “Individuals may make a reasonable statement of prognosis, but they shall not guarantee—directly or by implication—the results of any treatment or procedure.”; “may provide services via telepractice consistent with professional standards and state and federal regulations, but they shall not provide clinical services solely by written communication.”; “Individuals shall protect the confidentiality of information about persons served professionally”; “Individuals’ statements to the public shall adhere to prevailing professional standards and shall not contain misrepresentations when advertising, announcing, or promoting their professional services, products, or research.”.
3. American Occupational Therapy Association. Ethics (AOTA practice essentials page that publishes the 2025 code). Checked October 24, 2026.
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   “Occupational therapy personnel, including occupational therapists, occupational therapy assistants, and students, have an obligation to demonstrate ethical conduct that reflects professional values when working with clients, families, caregivers, administrators, colleagues, policymakers, payers, and other health care professionals.”; “AOTA 2025 Occupational Therapy Code of Ethics”.
4. American Occupational Therapy Association. AOTA Occupational Therapy Code of Ethics: Core Values and Principles (infographic, PDF, copyright 2025; the principles it lists include veracity). Checked October 24, 2026.
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   “Core values and principles are aspirational goals to help guide professional behavior and promote integrity, compassion, and respect for all individuals.”; “Sanctionable offenses and violations of ethical standards are addressed separately under the Code’s Standards of Conduct, which outline specific and enforceable behaviors.”; “Veracity”.
5. Federation of State Boards of Physical Therapy. The Model Practice Act for Physical Therapy, Seventh Edition (model statute and commentary for state practice acts, PDF, version 7.0, revised 2022). Checked October 24, 2026.
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   “Even where sections of existing jurisdiction law may differ from the Model Practice Act”; ““Consultation” means a physical therapist seeking assistance from, or rendering professional or expert opinion or advice to, another physical therapist or professional healthcare provider via electronic communications, telehealth, or in-person.”; ““Physical therapist-patient/client relationship” means the formal or inferred relationship entered into by mutual consent between a licensed physical therapist and a patient/client or their legally authorized representative established once the physical therapist assumes or undertakes the care or treatment of a patient/client”; “Examining, evaluating, and testing patients/clients with mechanical, physiological and developmental impairments, functional limitations, and disabilities or other health and movement -related conditions in order to determine a diagnosis, prognosis and plan of treatment intervention”.
6. U.S. Department of Health and Human Services, Telehealth.HHS.gov. Getting started with licensure (last updated February 21, 2024). “Health professionals must meet the licensure requirements of the state where they are located and be licensed or legally permitted to practice in the state where the patient is located.”. Checked October 24, 2026.
7. U.S. Department of Health and Human Services, Telehealth.HHS.gov. Licensing across state lines (last updated April 30, 2025). Checked October 24, 2026.
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   “The ability to deliver health care services across state lines varies based on state regulations.”; “Tip: Prior to an appointment, providers should verify patient location and obtain consent.”; “Multi-state licensure compacts streamline the licensing process across states, while preserving state oversight. Compacts allow participating health care providers to practice in participating states.”.
8. eCFR. 45 CFR 160.103, Definitions (HIPAA Administrative Simplification definitions; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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   “A health care provider who transmits any health information in electronic form in connection with a transaction covered by this subchapter.”; “Health information means any information, including genetic information, whether oral or recorded in any form or medium, that:”; “Relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual.”; “Individually identifiable health information is information that is a subset of health information, including demographic information collected from an individual”; “Transmitted or maintained in any other form or medium.”.
9. eCFR. 45 CFR 164.501, Definitions (HIPAA Privacy Rule definitions, designated record set; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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   “Used, in whole or in part, by or for the covered entity to make decisions about individuals.”; “the term record means any item, collection, or grouping of information that includes protected health information and is maintained, collected, used, or disseminated by or for a covered entity.”.
10. U.S. Department of Health and Human Services, Office of Inspector General. Office of Inspector General Policy Statement Regarding Gifts of Nominal Value To Medicare and Medicaid Beneficiaries (policy statement, December 7, 2016, PDF). Checked October 24, 2026.
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    “any remuneration that the person knows or should know is likely to influence the beneficiary’s selection of a particular provider, practitioner, or supplier of Medicare or Medicaid payable items or services may be liable for civil monetary penalties”; “transfers of items or services for free or for other than fair market value.”; “are interpreting “nominal value” as having a retail value of no more than $15 per item or $75 in the aggregate per patient on an annual basis.”; “the items may not be cash or cash equivalents. If a gift has a value at or below these thresholds, then the gift need not fit into an exception to section 1128A(a)(5).”.
11. eCFR. 42 CFR 1003.110, Definitions (OIG civil money penalty definitions, remuneration; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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    “includes the waiver of copayment, coinsurance and deductible amounts (or any part thereof) and transfers of items or services for free or for other than fair market value.”; “Items or services that improve a beneficiary’s ability to obtain items and services payable by Medicare or Medicaid, and pose a low risk of harm to Medicare and Medicaid beneficiaries and the Medicare and Medicaid programs by—”; “Being unlikely to interfere with, or skew, clinical decision making;”; “Being unlikely to increase costs to Federal health care programs or beneficiaries through overutilization or inappropriate utilization; and”; “Not raising patient safety or quality-of-care concerns;”.
12. Federal Trade Commission. Advertising FAQ’s: A Guide for Small Business (business guidance). Checked October 24, 2026.
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    “Advertising must be truthful and non-deceptive;”; “Advertisers must have evidence to back up their claims;”; “The FTC looks at what the ad does not say - that is, if the failure to include information leaves consumers with a misimpression about the product.”; “if you’re advertising a product as "free" or offering it at a low cost in conjunction with the purchase of another item, the ad should clearly and conspicuously disclose the terms and conditions of the offer. Disclose the most important information - like the terms affecting the cost of the offer - near the advertised price.”.
13. eCFR. 16 CFR Part 251, Guide Concerning Use of the Word “Free” and Similar Representations (Federal Trade Commission guide, section 251.1; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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    “The offer of “Free” merchandise or service is a promotional device frequently used to attract customers.”; “all such offers must be made with extreme care so as to avoid any possibility that consumers will be misled or deceived.”; “the word “Free” indicates that he is paying nothing for that article and no more than the regular price for the other.”; “When making “Free” or similar offers all the terms, conditions and obligations upon which receipt and retention of the “Free” item are contingent should be set forth clearly and conspicuously at the outset of the offer so as to leave no reasonable probability that the terms of the offer might be misunderstood.”; “disclosure of the terms of the offer set forth in a footnote of an advertisement to which reference is made by an asterisk or other symbol placed next to the offer, is not regarded as making disclosure at the outset.”; “may not be corrected by the substitution of such similar words and terms as “gift”, “given without charge”, “bonus”, or other words or terms which tend to convey the impression to the consuming public that an article of merchandise or service is “Free”.”.
14. eCFR. 45 CFR 149.610, Requirements for provision of good faith estimates of expected charges for uninsured (or self-pay) individuals (No Surprises Act rule; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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    “An individual who does not have benefits for an item or service under a group health plan”; “but who does not seek to have a claim for such item or service submitted to such plan or coverage.”; “must determine if an individual is an uninsured (or self-pay) individual by:”; “Informing all uninsured (or self-pay) individuals of the availability of a good faith estimate of expected charges upon scheduling an item or service or upon request;”; “Convening providers and convening facilities shall consider any discussion or inquiry regarding the potential costs of items or services under consideration as a request for a good faith estimate;”; “Orally provided when scheduling an item or service or when questions about the cost of items or services occur; and”; “When a good faith estimate is requested by an uninsured (or self-pay) individual: Not later than 3 business days after the date of the request.”; “the convening provider or convening facility must issue the good faith estimate to the uninsured (or self-pay) individual in written form”.
15. American Physical Therapy Association. Code of Ethics for the Physical Therapy Profession (APTA policies and bylaws page for the code, with its date). “Ethical conduct by physical therapists and physical therapist assistants is vital to the standing of the profession.”; “Date: January 1, 2026”. Checked October 24, 2026.
16. American Occupational Therapy Association. State Occupational Therapy Licensure (AOTA licensure page). Checked October 24, 2026.
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    “The ability to practice occupational therapy is regulated by state licensure agencies.”; “All 50 states in the United States plus the District of Columbia, Puerto Rico, and Guam require occupational therapists and occupational therapy assistants to be licensed to provide occupational therapy services.”; “A license grants you the legal privilege to practice occupational therapy in the state in which you are licensed.”.
17. American Speech-Language-Hearing Association. Telepractice (ASHA Practice Portal, professional issues). “Clinicians should verify state licensure/certification requirements in the state from which the clinician provides services as well as the state in which the client receives services prior to initiating services.”; “The state statutes and regulations take precedence over ASHA’s practice guidance.”. Checked October 24, 2026.
18. eCFR. 45 CFR 164.510, Uses and disclosures requiring an opportunity for the individual to agree or to object (HIPAA Privacy Rule, paragraph (b); eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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    “the protected health information directly relevant to such person’s involvement with the individual’s health care or payment related to the individual’s health care.”; “Obtains the individual’s agreement;”; “Provides the individual with the opportunity to object to the disclosure, and the individual does not express an objection; or”.
19. U.S. Department of Health and Human Services, Office for Civil Rights. Covered Entities and Business Associates (HIPAA for professionals; content last reviewed August 21, 2024). Checked October 24, 2026.
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    “but only if they transmit any information in an electronic form in connection with a transaction for which HHS has adopted a standard.”; “If an entity does not meet the definition of a covered entity or business associate, it does not have to comply with the HIPAA Rules.”; “If a covered entity engages a business associate to help it carry out its health care activities and functions, the covered entity must have a written business associate contract or other arrangement with the business associate”.
20. U.S. Department of Health and Human Services, Office for Civil Rights. May physician’s offices or pharmacists leave messages for patients at their homes (HIPAA FAQ, created December 19, 2002; content last reviewed December 28, 2022). Checked October 24, 2026.
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    “covered entities should take care to limit the amount of information disclosed on the answering machine”; “a covered entity might want to consider leaving only its name and number and other information necessary to confirm an appointment, or ask the individual to call back.”.
21. U.S. Department of Health and Human Services, Office for Civil Rights. Does the HIPAA Privacy Rule permit health care providers to use e-mail to discuss health issues and treatment with their patients? (HIPAA FAQ, created December 15, 2008; content last reviewed July 26, 2013). Checked October 24, 2026.
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    “provided they apply reasonable safeguards when doing so.”; “checking the e-mail address for accuracy before sending”; “Patients may initiate communications with a provider using e-mail. If this situation occurs, the health care provider can assume (unless the patient has explicitly stated otherwise) that e-mail communications are acceptable to the individual.”.
22. U.S. Department of Health and Human Services, Office of Inspector General. General Questions Regarding Certain Fraud and Abuse Authorities (OIG FAQ, last updated April 23, 2026). Checked October 24, 2026.
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    “The Beneficiary Inducements CMP provides for the imposition of CMPs against any person who offers or transfers remuneration to a Medicare or State health care program beneficiary that the person knows or should know is likely to influence the beneficiary’s selection of a particular provider, practitioner, or supplier”; “the Federal anti-kickback statute is an intent-based criminal statute prohibiting the exchange of anything of value for Medicare and other Federal health care program referrals.”.
23. American Physical Therapy Association. Direct Access Advocacy (APTA advocacy page). Checked October 24, 2026.
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    “As of July 1, 2025, all 50 states, the District of Columbia, and the U.S. Virgin Islands have either provisional or unrestricted direct access to physical therapist services for evaluation and treatment.”; “some provisions tied to treatment absent a referral still persist in a number of states”.
24. eCFR. 42 CFR 440.110, Physical therapy, occupational therapy, and services for individuals with speech, hearing, and language disorders (Medicaid services definitions; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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    “Physical therapy means services prescribed by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law”; “Occupational therapy means services prescribed by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law”; “for which a patient is referred by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law.”.
25. eCFR. 42 CFR 424.24, Requirements for medical and other health services furnished by providers under Medicare Part B (paragraph (c), outpatient physical therapy, occupational therapy and speech-language pathology services; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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    “If the plan of treatment is established by a physical therapist, occupational therapist, or speech-language pathologist, the certification must be signed by a physician or by a nurse practitioner, clinical nurse specialist, or physician assistant who has knowledge of the case, except as specified in paragraph (c)(5) of this section.”; “and there is a written order or referral from the individual’s physician, nurse practitioner (NP), physician assistant (PA), or clinical nurse specialist (CNS) in the patient’s record and the therapist has documented evidence that the plan of treatment has been delivered to the physician, NP, PA, or CNS within 30 days of completion of the initial evaluation, the certification does not need to be signed by a physician, NP, CNS, or PA who has knowledge of the case.”; “No references to an order or referral in this subsection shall be construed to require an order or referral for outpatient physical therapy, occupational therapy, or speech-language pathology services.”.
26. U.S. Department of Justice, Civil Rights Division. ADA Requirements: Effective Communication (ADA.gov guidance, last updated February 28, 2020). Checked October 24, 2026.
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    “title III entities (businesses and nonprofit organizations that serve the public) communicate effectively with people who have communication disabilities.”; “The rules apply to communicating with the person who is receiving the covered entity’s goods or services as well as with that person’s parent, spouse, or companion in appropriate circumstances.”; “Covered entities are also required to accept telephone calls placed through TRS and VRS, and staff who answer the telephone must treat relay calls just like other calls.”; “They cannot require a person to bring someone to interpret for him or her.”.
27. Federal Communications Commission. Telecommunications Relay Service - TRS (consumer guide, last updated or reviewed August 16, 2022). Checked October 24, 2026.
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    “Telecommunications Relay Service allows persons with hearing or speech disabilities to place and receive telephone calls.”; “you can dial 711 to connect to certain forms of TRS anywhere in the United States.”; “Speech-to-Speech Relay Service is used by a person with a speech disability.”; “Some people hang up on TRS calls because they think the CA is a telemarketer.”.
28. eCFR. 45 CFR 92.4, Definitions (Section 1557 rule; eCFR text up to date as of October 22, 2026). “Covered entity means:”; “A recipient of Federal financial assistance;”. Checked October 24, 2026.
29. eCFR. 45 CFR 92.201, Meaningful access for individuals with limited English proficiency (Section 1557 rule; eCFR text up to date as of October 22, 2026). Checked October 24, 2026.
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    “A covered entity must take reasonable steps to provide meaningful access to each individual with limited English proficiency”; “Language assistance services required under paragraph (a) of this section must be provided free of charge, be accurate and timely, and protect the privacy and the independent decision-making ability of the individual with limited English proficiency.”; “When interpretation services are required under this part, a covered entity must offer a qualified interpreter in its health programs and activities.”; “Require an individual with limited English proficiency to provide their own interpreter, or to pay the cost of their own interpreter;”.

Medical disclaimer. This page is for general educational purposes and does not constitute medical advice, diagnosis, or treatment. It is general guidance on running a therapy practice, not legal, compliance, billing or financial advice. Licensure, privacy, beneficiary-inducement and advertising questions turn on the state, the payer and the practice’s facts, and its examples are hypothetical, not DrSensory data or benchmarks.