For therapists

How to run therapy groups in an OT, PT or SLP practice

When a group is the right clinical format, how Medicare and other payers define and code group therapy, consent and privacy, access, staffing and assistants, honest program marketing, and the templates to run a group.

  • Sources Cited
  • Template Included
  • For Clinicians

This guide is for OT, PT and SLP practices planning groups for children or adults. Run a group when each participant’s evaluation and plan of care call for one: set individual goals, check each payer’s group definition and code, get consent to the group format, keep a therapist in constant attendance, and promote only what the evidence supports.

Key takeaways

  • Medicare pays for outpatient group therapy given to two or more people at once, who need not do the same activity, with the therapist in constant attendance; its manual sets no maximum group size, though a Medicare contractor may.⁠1,2
  • When a therapist divides attention among patients with only brief, intermittent contact, CMS counts it as group therapy, and each patient is billed one untimed unit of 97150 rather than individual timed units.⁠3
  • SLPs report group treatment with 92508, which ASHA describes as revised into a stand-alone group code alongside the new individual codes that replace 92507 on January 1, 2027.⁠4,5
  • Payers add their own conditions: UnitedHealthcare’s commercial policy and Texas Medicaid both ask for a prescriber’s order for group therapy and an individualized plan for each member.⁠6,7
  • HIPAA treats what is shared in a group therapy session as treatment disclosures, and a person’s agreement to join is a good basis for inferring their agreement; the other members are not bound by HIPAA.⁠8,9
  • Medicare does not recognize SLPA services; PTAs and OTAs may treat in private practice under general supervision, and state rules on support personnel vary widely.⁠1,10,11,12
  • Consumer testimonials are not competent and reliable scientific evidence, and giving an incentive in exchange for reviews that express a particular sentiment violates the FTC’s review rule.⁠13,14

Two kinds of group have guides of their own: handwriting groups for children have the handwriting and fine-motor program guide, and recreation and sports programs have the adaptive sports and teen-athlete guide.

When is a group the right format for therapy?

When each participant’s evaluation shows goals a group can serve, alone or alongside individual sessions, and each person still needs a therapist’s skilled care during the session. ASHA’s guidance on documenting group therapy asks a practice to identify why services were delivered in a group, to show that the group was part of an individualized plan of care, and never to run a group for the convenience of the clinician or facility.⁠2 Medicare’s test is skill: services that do not require the performance or supervision of a therapist are not skilled therapy, and CMS states that supervising patients who exercise independently is not a skilled service.⁠1,3

SignalPoints toward a groupPoints toward individual sessions
GoalPracticing a skill with peers or in a natural context, such as conversation, turn-taking or balance while movingLearning a new skill step by step, or a goal no one else in the group shares
ParticipationCan take part for the whole session with the supports the group offersNeeds hands-on help, constant one-to-one cueing or a pace the group cannot hold
SafetyRisks the staffing covers, such as standby guardingRisk of a fall, choking or distress that needs one clinician’s full attention
PaymentThe person’s plan pays for group treatment of this kind, or they choose self-payTheir plan pays only for one-to-one treatment
PreferenceThe person or family wants peer practiceThe person wants privacy, or a group would reveal more than they want to share

Is a community class the same as a therapy group?

No. A class anyone may join, with no evaluation, plan of care or individual goals, is instruction or fitness, and is described and priced that way. APTA’s pediatric academy describes physical therapists referring children to community fitness staff for long-term fitness programs once therapy goals are met, and notes that payment differs with the family’s insurance, the setting and the type of intervention.⁠15 Keep such a class off therapy claims unless it meets the clinical steps above. The adaptive sports guide sets out where skilled physical therapy ends and a wellness program begins.

Which decisions does a therapy group need before it opens?

Nine, each settled on paper before the group is advertised:

DecisionSettleRecorded as
Clinical purposeThe shared skill, and why practicing it with peers helpsA one-sentence group definition
Who fitsAges, the evaluation findings that qualify someone, and where others are sentEntry and exit criteria stated in terms of the activity
Format and sizeGroup only, or alongside individual sessions; the maximum number of membersA size rule with its reason
StaffingThe leader, any assistant or student, and supervision under state rulesA staffing plan for each session
Payer and codeEach plan’s group definition, code, order requirement and size limitA payer grid
Consent and privacyThe group agreement, privacy safeguards and photo rulesA signed agreement for each member
AccessCommunication aids, physical access, schedule and costAn access checklist
MeasuresEach member’s goals and how progress is recordedA data method for each goal
WordingEvery claim on the service page, flyer and listing, with its sourceReviewed public wording

Demand and capacity for any new service are tested in the specialty guide.

Which therapy groups do OT, PT and SLP practices run?

Each discipline runs groups within its own scope, for children and for adults, and the scopes overlap. Adult social communication groups, for example, are offered by psychologists and counselors as well as SLPs, and the Stepping On falls program, a small-group program for older adults, included a follow-up occupational therapy home visit.⁠16,17

DisciplineGroups for childrenGroups for adultsWhat the profession’s guidance says
SLPSocial communication and social skills groups; group language practiceAphasia and conversation groups; social skills and life skills groupsASHA: social skills groups typically have two to eight members and a facilitator and are used from school age to adulthood; in aphasia, group treatment is often used to apply learned strategies in conversation⁠16,18
OTParticipation groups for play, self-care and school tasks; handwriting groups; sensory-informed groups where each child’s assessment supports themFalls-prevention and home-safety groups; daily-living groups built on each person’s goalsAOTA’s 5-to-21 guideline finds support for group service models and for peer-mediated models; AOTA’s Practice Smart list: no sensory-based intervention for a child without documented assessment results, and no non-purposeful activities such as cones and pegs⁠19,20
PTGross motor and fitness groups for children with disabilitiesBalance and strength groups for older adults; circuit classes after stroke; exercise groups for joint conditionsAPTA’s pediatric academy notes that APTA’s Guide puts prevention, health promotion, wellness and fitness within PT scope; the evidence for adult groups is in the next section⁠15

A feeding group needs its own food-safety plan and competence record, both covered in the feeding and swallowing guide. In a co-led group, each clinician’s role is written down and stays within that clinician’s license.

What does the evidence say about group therapy formats?

It supports specific group programs for specific people, at very different strengths. Report each finding at the strength its authors give it.

Group formatWhat the research foundStrength, as the authors report it
Social skills groups, autistic people aged 6 to 21Some evidence of better social competence and friendship quality; 5 RCTs, 196 participants⁠21High risk of performance and detection bias; mostly children aged 7 to 12 of average or above-average intelligence⁠21
Group social skills interventions, autistic youthA medium overall effect across 19 RCTs⁠22Modest; may not carry over to school settings or self-reported social behavior⁠22
Outpatient and community aphasia groupsCan improve specific linguistic processes; 29 studies⁠23Limited evidence of better functional communication⁠23
Circuit class therapy after strokeWalking further and faster, with more independence and balance confidence; 17 RCTs, 1,297 participants⁠24Moderate; the risk of falls during sessions needs monitoring⁠24
Balance and functional exercise, older adultsA 24 percent lower rate of falls across 39 studies⁠25High certainty, from trials of any form of exercise, so it supports a balance group’s content rather than the group format⁠25
Stepping On, adults 70 and older31 percent fewer falls in one randomized trial of 310 people, with seven weekly two-hour small-group sessions and an OT home visit⁠17A single trial, published in 2004⁠17
Group fitness, children with disabilitiesFunctional mobility improved and no injuries were reported in 28 children aged 6 to 14⁠26Pretest-posttest design with no control group⁠26

AOTA’s practice guideline for ages 5 to 21, built on three systematic reviews, also recommends skills-based training and practice in valued occupations over isolated sensorimotor approaches, a reason to build an OT group around real tasks rather than equipment.⁠19

Does group therapy work as well as individual therapy?

Few trials compare the two head to head. In one that did, 320 veterans with knee osteoarthritis were randomized to six one-hour group PT sessions, typically 8 people per group, or two one-hour individual sessions, and group PT was not more effective than individual PT on the study’s outcomes.⁠27 Other studies above compare a group with something else: the social skills review with no intervention, a wait list or usual care, and the circuit class review with other interventions.⁠21,24 Those trials show that a group program can help, not that it matches individual care, so do not claim equivalence in your materials.

How does Medicare define group therapy for outpatient services?

As treatment given at the same time to two or more people, who need not be doing the same activity, by a therapist in constant attendance, with no one-on-one contact required.⁠1 The definition covers outpatient PT, OT and speech-language pathology. The manual sets no limit on group size, but ASHA notes that a Medicare Administrative Contractor’s local coverage determination can; its example is a limit of four patients, or group therapy for only 25 percent of treatment time in an episode.⁠2

CMS’s billing scenarios for PTs and OTs draw the line by how the therapist spends the time. When the therapist divides attention among patients, with only brief, intermittent contact or the same instructions to several at once, each patient is billed one untimed unit of 97150.⁠3 The same scenarios say group sessions should be long enough to meet each patient’s needs, that a private practice should bill 97150 only once a day per patient, and that a group and an individual session on the same day must be distinct and billed with modifier 59.⁠3 APTA reports concerns about outpatient practices using one-on-one codes where the group code applies.⁠28

Every member still needs their own plan of care. Medicare payment depends on a physician’s or NPP’s certification of the plan rather than on an order, and progress reports are due at least once every 10 treatment days.⁠1

How do group, individual and concurrent therapy differ?

By how many people the therapist treats at once and whether they share an activity, and the definitions differ between outpatient Part B and skilled nursing facility Part A.

ModeOutpatient Medicare Part BSkilled nursing facility, Medicare Part A
IndividualDirect one-on-one contact, billed with timed codes in 15-minute units under the 8-minute rule⁠3,29One therapist or assistant with one resident at a time⁠30
GroupTwo or more people doing the same or different activities, therapist in constant attendance; 97150 or 92508, one untimed unit each⁠1,4,29Two to six residents doing the same or similar activities, with a therapist or assistant supervising no one else⁠30
ConcurrentNot a separate mode: two people treated at once, doing similar or different activities, without identifiable one-on-one episodes, are billed as group⁠3Two residents at once who are not doing the same or similar activities, both in the therapist’s line of sight⁠30
LimitNone in the manual; check the contractor’s LCD⁠2Concurrent and group therapy combined held to 25 percent of each discipline’s minutes; going over brings a warning edit, not a penalty⁠30

APTA has warned that some SNFs misread the 25 percent limit as a mandate to deliver that much group therapy.⁠31

Which CPT codes apply to group therapy in OT, PT and SLP?

97150 for PT and OT groups and 92508 for groups treating speech, language, voice, communication or auditory processing disorders, each reported as one untimed unit per member per session.⁠3,4,29

CodeWho reports itWhat to know
97150, therapeutic procedure(s), groupPTs and OTsUntimed, one unit per patient; NCCI policy says SLPs do not perform it, though some contractors let SLPs use it for cognition or dysphagia groups⁠3,32
92508, group treatment, 2 or more individualsSLPsUntimed; revised into a stand-alone group code alongside the new individual codes that replace 92507 on January 1, 2027; not reported with 97154 or 97158⁠4,5
92507, and its timed replacements from January 1, 2027SLPsIndividual treatment only; other payers decide if and when to adopt the new codes⁠5
97552, group caregiver trainingListed by ASHA among Medicare codes for SLPsSeveral sets of caregivers trained together, without the patient present; new in 2024⁠32

No CPT code describes group therapy for dysphagia or cognition, and ASHA advises against using 92508 for disorders it does not describe unless the LCD permits it.⁠2

How do commercial plans and Medicaid treat group therapy?

Each sets its own terms, so check the plan before anyone enrolls. UnitedHealthcare’s commercial policy asks that group therapy records include the prescribing provider’s order, an individualized plan with the group’s frequency, duration and goals, the supervising therapist’s name and signature, and the number of clients in the group.⁠6 Texas Medicaid requires a prescription for group therapy, an individualized plan for each client and a therapist in constant attendance in the same room; it sets no limit on group size but holds providers to their licensure boards’ standards, and it lets PT and OT providers bill 97150 for each group member, children and adults alike.⁠7 Medicare, by contrast, requires a certified plan rather than an order.⁠1

Medicaid coverage itself varies. For adults, physical therapy, occupational therapy and speech, hearing and language services are optional state plan benefits; children under 21 in Medicaid have the EPSDT benefit, under which each state decides medical necessity case by case.⁠33,34 Self-pay members are usually owed a good faith estimate of expected charges when they ask for one or book three or more business days in advance.⁠35 Explaining what a plan pays, to families and to adult clients, is the subject of the insurance and fees guide.

Can two therapists co-lead a group and both bill for it?

Not for the same time with the same people, under CMS’s PT and OT scenarios. Therapists or assistants working together as a team cannot each bill separately for services given at the same time to the same patient; when a PT and an OT treat one patient together, one bills the whole service or they divide the units.⁠3 Those scenarios are written for PTs and OTs, so an SLP co-leading with an OT should ask the Medicare contractor and each plan how they apply. A co-led group can still be the right design: decide in writing who leads, who documents and who bills.

What should participants agree to before joining a group?

To the group format itself, on top of consent to treatment: who else attends, what others may hear, how individual progress is discussed, photos, attendance and cost. Each discipline’s code asks for that disclosure. ASHA requires SLPs to obtain informed consent covering what a service involves and its possible risks and effects, and to tell people the name, role and credentials of whoever provides their care; APTA requires PTs to give patients or their surrogates the information needed for informed decisions; and AOTA’s code rests on principles that include autonomy and veracity.⁠36,37,38

Who signs depends on age and capacity. An adult decides for themselves unless a legal representative acts for them, and ASHA asks SLPs who suspect diminished decision-making ability to seek authorization from a legally authorized representative.⁠36 For a child, HHS explains that in most cases a parent acts as the minor’s personal representative, with exceptions that follow state laws allowing minors to consent to some care themselves.⁠39 Explain the agreement directly to a teenager in a teen group as well.

Group agreement: [the group’s name]

  • What this group is: [the discipline] therapy for up to [number] members, led by [the therapist’s full name and credentials], with [any assistant or student, and their role], on [day, time and place], for [number] sessions.
  • Why a group: your goals from your evaluation include [the shared skill]; you also have [individual sessions, or none], and you may ask to change format at any time.
  • What others see and hear: other members, and any family members who attend, see who comes and hear what is said in the session.
  • What stays private: your evaluation, goals and progress are discussed with you, or with your parent or representative, in private, never in front of the group; rosters and name tags show first names only.
  • What we ask of every member: keep other members’ names, stories and health details to yourself, and take no photos, recordings or posts during sessions.
  • Photos and stories: none are used without a separate signed authorization, which you may refuse without any effect on your care.
  • Attendance: [what happens after a number of missed sessions, and how a place is held].
  • Safety: [the safety plan in plain words, such as guarding during balance work or where a child goes for a break].
  • Cost: [the fee per session, what your plan is billed, and any estimate given].
  • Leaving: you may leave the group at any time; tell [the contact] so your plan can be updated.
  • Signed: [the member, or the parent or legal representative], on [the day signed]

How does HIPAA apply when patients hear each other in a group?

It permits it. HHS treats disclosures of health information in a group therapy setting as treatment disclosures that need no authorization, allows disclosure to a family member involved in the person’s care, and says agreeing to join a group is a good basis for inferring a person’s agreement.⁠8 The practice still needs safeguards: HHS permits incidental disclosures only where reasonable safeguards and minimum necessary policies are in place, and an incidental disclosure caused by skipping them is not permitted.⁠40 HHS’s sign-in example applies to group check-in, since a sign-in sheet may not show medical information that signing in does not need, such as the patient’s problem.⁠41

The other members are neither covered entities nor business associates, and HIPAA does not bind anyone who is neither.⁠9 The agreement’s request to keep confidences is therefore a request, not a HIPAA duty. Say so plainly, and keep what is said in the room to what the session needs.

Can you invite patients to a group or post photos of it?

Inviting current patients to the practice’s own new group is generally not HIPAA marketing, because the definition excepts a covered entity’s communications about its own services; HHS’s example is a hospital using its patient list to announce a new specialty group.⁠42 Posting a group photo, a member’s name or their story is different: unless another rule permits a use, HIPAA requires a valid authorization, so get each member’s, or parent’s, signed authorization first, for everyone in the frame.⁠43

How do you make a therapy group accessible to every participant?

Write entry criteria around what the activity needs, provide communication aids at no extra charge (the no-surcharge rule is below), and schedule for the people the group serves. Under ADA Title III, a business serving the public may not use eligibility criteria that screen out people with disabilities unless the criteria are necessary for the service, and must make reasonable modifications unless they would fundamentally alter it.⁠44,45 For a balance group, "stands for two minutes with standby assistance" is a criterion tied to the activity; "no walkers" is not.

The ADA obliges businesses open to the public to make communication with people who have communication disabilities as effective as with anyone else, choosing the aid by the nature, length, complexity and context of the communication, and a business cannot require a person to bring their own interpreter.⁠46 A business may not add a surcharge to cover auxiliary aids, so an interpreter or captioning for one member is a practice cost, not that member’s fee.⁠44

Timing matters as much: school-age groups compete for after-school hours, and adult groups depend on work hours and transport. Running both age tracks from one timetable is the subject of the children-and-adults launch guide.

How many participants can one therapist lead in a group?

As many as one therapist can keep in constant attendance while giving each person skilled care toward their own goals, and the number belongs in the program in writing. Medicare’s manual sets no maximum, a contractor’s LCD may set one, and Texas Medicaid sets none but holds providers to their licensure boards’ standards.⁠2,7 Set the ratio from risk as well as goals; the Cochrane review of circuit class therapy after stroke says the risk of more falls during sessions needs monitoring.⁠24

RoleIn a groupUnder Medicare Part B
PT, OT or SLPEvaluates, writes each plan, leads and documentsBills the service; payment rests on a certified plan of care⁠1
PTA or OTALeads or assists under the therapist’s plan; no evaluation, clinical judgments or decisionsThe therapist reports the assistant’s group time; general supervision in private practice; claims carry the assistant modifier and are paid at 85 percent⁠1,3,10,11,47
SLPADuties set by state law⁠48Services not recognized for Medicare coverage⁠1
AideSet-up, transport and non-skilled helpNot therapy and not covered⁠1
StudentTakes part under the therapist’s directionA therapist’s group may be billed with a student in the room; the student’s own services are not paid⁠1

State rules decide the rest. APTA notes that requirements for the use of personnel vary widely from state to state, ASHA that rules for SLP support personnel vary from state to state in education, supervision and titles, and CMS that the level and frequency of supervision differs by setting and by state or local law.⁠1,12,48 CMS’s own manual and its Part B billing scenarios have not caught up: both still describe direct, in-office supervision of PTAs and OTAs in private practice, while the regulations now allow general supervision, a change APTA ties to 2025; follow the current regulation and any stricter state rule.⁠1,3,10,12

What goes in a therapy group design worksheet?

The decision table turned into a form: one line per decision, a named person for each, and a date. Fill it in before anything is published and revisit it when the first cycle of sessions ends.

Therapy group design worksheet

  • Group definition: [discipline, shared skill and format, in one sentence]
  • Who it serves: [ages; what the evaluation must show, in terms of the activity; where others are referred]
  • Format: [group only, or alongside individual sessions; session length, frequency and number of sessions]
  • Maximum size: [number, and the reason, such as guarding needs or communication supports]
  • Staffing: [the leader, any assistant or student, and the state supervision rule that applies]
  • Payers: [for each plan: group definition, code, order requirement and size limit; the self-pay fee and estimate process]
  • Consent and privacy: [the agreement version, who signs for minors and represented adults, and the roster, check-in and photo rules]
  • Access: [communication aids, room access, schedule]
  • Measures: [each goal’s data method, and the review points]
  • Discharge: [goals met, no further benefit expected, or the member’s choice]
  • Public wording: [where the description appears, and the source behind each claim]
  • Kept by: [the person responsible, and the month of the next review]

What does a therapy group session plan include?

Each member’s goal for the session, how it is measured, who does what, and what the note must record for the payer. Payers set many of the note’s fields: UnitedHealthcare asks for the techniques used and how they restore function, the session length, the setting and the number of clients, and Texas Medicaid asks for start and stop times as well.⁠6,7

Session plan: [the group’s name], session [number] of [total]

  • Date and time: [start and stop times]
  • Leader and helpers: [the therapist, and any assistant or student with their tasks]
  • Members present: [first names or record numbers, and the total]
  • Shared activity: [what the group does together, and why it serves the members’ goals]
  • Each member’s target: [member, goal for today, the support or cue level, how it is scored]
  • Safety: [guarding positions, break plan, emergency steps]
  • Communication supports: [visuals, interpreter, captioning, device]
  • One-on-one moments: [planned individual episodes, if any; individual billing needs its own distinct session]
  • Note for each member: [the techniques used and how they serve the goal, the response, the data, and the next step]

How should you track progress for each group member?

Individually, against each person’s own goals, never as a group average. Medicare requires a progress report at least once every 10 treatment days; ASHA’s code lets an SLP provide services only when benefit can reasonably be expected, and APTA’s asks PTs to avoid overutilization, so a member who stops progressing needs a changed plan rather than more sessions.⁠1,36,37 For OT groups, AOTA’s Practice Smart list adds that no intervention should start before the client’s occupational profile is complete and goals are set together.⁠20

How should you describe a therapy group in your marketing?

With facts a reader can check: the members it serves, what a session involves, how each person’s progress is measured, the fee, and the limits of what it can do. The FTC’s small-business guide sets two basics, that ads be truthful and non-deceptive and that advertisers hold evidence for their claims; its health guidance extends the same principles to any health-related product, and the FTC Act’s false-advertising section covers services.⁠49,50 The professional codes agree: ASHA allows an SLP a reasonable prognosis and forbids promising treatment results, openly or by implication; APTA requires truthful, accurate information without misleading representations; and AOTA names veracity as a principle.⁠36,37,38

Instead ofWrite
"Make friends in eight weeks""Eight sessions practicing conversation with peers, led by a speech-language pathologist; goals come from your child’s evaluation"
"Fall-proof your balance""A balance and strength group for adults whose evaluation shows a fall risk, with balance measured at the start and the end"
"Clinically proven program""Studies of similar programs found [what the cited study found, at its stated strength]"
"As effective as private sessions, for less""A group format, with your own goals and your own progress report"

On DrSensory, describe the group in the description field of a paid listing, written by the clinic, and reflect it in the listing’s specialties, ages and conditions treated. The basic listing costs nothing, and claiming it is free. DrSensory does not promise rankings or check clinical quality, so the listing needs the same sourced wording as your pediatric and adult service pages.

Can you use group members’ testimonials in your marketing?

Only with care on three counts. The FTC treats a client’s story about a central result as a message that most people get that result, and testimonials do not count as the scientific evidence a health claim needs.⁠13 A free or discounted session can be a material connection that must be disclosed when readers would not expect it, and giving an incentive in exchange for reviews that express a particular sentiment violates the FTC’s review rule.⁠14,51 Under HIPAA, a testimonial that names a patient or tells their story needs their signed authorization.⁠43 For asking clients for reviews and replying to them, see the reviews guide.

Can a free community class promote a therapy group?

Yes, with care when attendees have Medicare or Medicaid. OIG’s 2016 policy statement treats services given free as remuneration, and remuneration a provider knows or should know is likely to sway a beneficiary toward that provider can draw civil monetary penalties; a gift at or under OIG’s nominal-value line, a retail value of $15 an item and $75 a year per patient, needs no exception.⁠52 A free fall-prevention talk for older adults is the common case: write down what is offered and what it is worth, keep it to education rather than treatment, and have the arrangement reviewed before you publicize it. Talks to parents are covered in the parent-group talk guide.

How does one clinic plan a children’s group and an adult group?

Two groups at one hypothetical clinic show how the same steps change with age and payer.

Hypothetical. A clinic with two SLPs, one OT, two PTs and a PTA plans two groups: a social communication group for children aged 8 to 10, and a balance group for adults over 65.

The children’s group. The SLP writes the definition first: up to four children whose evaluations show conversation goals to practice with peers, 60 minutes a week for ten weeks. Of six children evaluated, four join, one starts with individual sessions to learn a new skill first, and one is referred to a psychologist. Two plans accept 92508, a third asks for a prescriber’s order for group therapy, which the SLP requests before the first session, and one family pays privately and receives a good faith estimate. Every family signs the group agreement, and rosters show first names only.

The adult group. The PT sets the size at six with the PTA assisting, because two members use walkers and need standby guarding. Each member has an evaluation, a certified plan of care and individual balance goals. Medicare Part B is billed one unit of 97150 per member per session; because the PT and PTA treat the same members at the same time, the session is billed once, not once for each of them. A free fall-prevention talk at the senior center is open to anyone, with the same handout for all and nothing else of value given.

What changed. The children’s page now says "practice conversation with peers; goals from your child’s evaluation" instead of "make friends fast", and the adult flyer names the evaluation, the group size and how balance is measured.

Every number in the example is invented to show the steps, not a benchmark for enrollment or payer mix.

Frequently asked questions

Can an SLP bill 97150 for a dysphagia or cognition group?

Usually not. NCCI policy lists 97150 among codes SLPs do not perform, and no CPT code describes group therapy for dysphagia or cognition, but some contractors’ LCDs let SLPs use 97150 for those groups.⁠2,32

Can a therapy assistant lead a group session?

A PTA or OTA can, under the therapist’s plan and supervision and within state law, with the therapist reporting the assistant’s group time; neither may evaluate or make clinical decisions, and Medicare does not recognize SLPA services.⁠1,3,10,11

Can parents sit in on a children’s therapy group?

If the group agreement allows it. HIPAA generally permits disclosure to a family member involved in a person’s care, and HHS reads agreement to a group or family discussion as a good basis for inferring the person’s agreement; decide in advance whether parents watch, join or wait, because other families’ children are in the room.⁠8

Is a parent training group without the child billable?

Sometimes. ASHA lists 97552 among Medicare codes for SLPs, for training several sets of caregivers together without the patient present, new in 2024; confirm the plan covers it before you schedule one.⁠32

Can I bill individual codes if each member gets some one-on-one time?

Only for identifiable one-on-one episodes long enough to deliver skilled treatment; if you are dividing attention with brief, intermittent contact, CMS treats the session as group therapy and each patient gets one unit of 97150.⁠3

Should a group member also have individual sessions?

When the evaluation calls for it. ASHA describes group work in aphasia and social communication as used in addition to one-on-one treatment, and CMS allows a group and an individual session on the same day when they are distinct.⁠3,16,18

Does a self-pay group member need a good faith estimate?

Usually, yes. When someone is not using insurance, CMS says the provider usually owes them a good faith estimate if they request one or book a service at least 3 business days in advance.⁠35

Can a DrSensory listing show our therapy groups?

It can: the clinic describes its groups in its own words in a paid listing’s description and lists the matching specialties, ages and conditions. Claiming costs nothing; on the pricing page, a paid listing for one location is $29.99 monthly or $349.99 yearly, with no contract, and each further location is $9.99 a month or $99.99 a year.

Sources

  1. Centers for Medicare & Medicaid Services. Medicare Benefit Policy Manual, Chapter 15, Covered Medical and Other Health Services (sections 220.1.1, 220.2, 220.3, 230.A, 230.B, 230.1 and 230.3). Checked October 23, 2026.
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    “Although there is no Medicare requirement for an order”; “Payment is dependent on the certification of the plan of care rather than the order”; “Services that do not require the performance or supervision of a therapist are not skilled and are not considered reasonable or necessary therapy services”; “The minimum progress report period shall be at least once every 10 treatment days.”; “Contractors pay for outpatient physical therapy services (which includes outpatient speech-language pathology services) and outpatient occupational therapy services provided simultaneously to two or more individuals by a practitioner as group therapy services (97150).”; “The individuals can be, but need not be performing the same activity.”; “The physician or therapist involved in group therapy services must be in constant attendance, but one-on-one patient contact is not required.”; “The services performed by a student are not reimbursed even if provided under “line of sight” supervision of the therapist”; “Group therapy services performed by a therapist or physician may be billed when a student is also present “in the room”.”; “PTAs may not provide evaluative or assessment services, make clinical judgments or decisions”; “The level and frequency of supervision differs by setting (and by state or local law).”; “General supervision is required for PTAs in all settings except private practice (which requires direct supervision)”; “Services provided by aides, even if under the supervision of a therapist, are not therapy services and are not covered by Medicare.”; “Services of speech-language pathology assistants are not recognized for Medicare coverage.” The OTA passages in section 230.2 match the PTA passages quoted here.
  2. American Speech-Language-Hearing Association. Medicare Guidelines for Group Therapy (Reimbursement, Medicare). Checked October 23, 2026.
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    “For example, a MAC could define group therapy as no more than four patients, restrict the use of groups to speech-language therapy, and/or allow group therapy for only 25% of the total treatment time per episode.”; “identify why services were delivered in a group setting;”; “establish that group therapy services were provided as part of an individualized plan of care;”; “Group therapy should never be provided for the convenience of the clinician or facility.”; “The Medicare Benefit Policy Manual does not establish a specific restriction on the use of group therapy, particularly as it pertains to the size of the group.”; “There are no CPT codes that describe group therapy for other disorders, such as dysphagia or cognition.”; “However, CPT code 92508 should not be used to report treatment of disorders not described by the code unless specifically permitted under the LCD.”; “Some LCDs may also allow speech-language pathologists to use CPT code 97150 (therapeutic procedure(s), group) to describe group therapy for other disorders, such as dysphagia.”
  3. Centers for Medicare & Medicaid Services. 11 Part B Billing Scenarios for PTs and OTs (Individual vs. Group Treatment; marked “Reviewed 9/2009”, linked from the CMS Therapy Services page last modified March 10, 2026). Checked October 23, 2026.
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    “If the therapist is dividing attention among the patients, providing only brief, intermittent personal contact, or giving the same instructions to two or more patients at the same time, it is appropriate to bill each patient one unit of group therapy, 97150 (untimed).”; “Therapists, or therapy assistants, working together as a "team" to treat one or more patients cannot each bill separately for the same or different service provided at the same time to the same patient.”; “Where a physical and occupational therapist both provide services to one patient at the same time, only one therapist can bill for the entire service or the PT and OT can divide the service units.”; “Therefore, group therapy sessions should be of sufficient length to address the needs of each of the patients in the group.”; “However, the group therapy session must be clearly distinct or independent from other services and billed using a -59 modifier.”; “Supervising patients who are exercising independently is not a skilled service.”; “The therapist reports the time the therapy assistant provides care, whether it is one-on-one care or delivered via the untimed codes, such as supervised modalities or group therapy.”; “The therapist cannot bill for his/her services and those of another therapist or a therapy assistant, when both provide the same or different services, at the same time, to the same patient(s).”; “In private practice settings for physical and occupational therapists and in physician offices where therapy services are provided incident to the physician, Medicare expects the group therapy code (97150) to be billed only once each day per patient.”; “Each direct one-on-one episode, however, should be of a sufficient length of time to provide the appropriate skilled treatment in accordance with each patient’s plan of care.”; “direct ("in the office suite") supervision in private practice PT or OT therapy settings”; “under Part B, the therapeutic interventions can be similar or different”.
  4. American Speech-Language-Hearing Association. Treatment Code Family Replacing 92507 (Group Treatment Code). Checked October 23, 2026.
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    “CPT code 92508 has been revised as a stand-alone code for group treatment of speech, language, voice, communication, and/or auditory processing disorders involving two or more individuals.”; “Treatment of speech, language, voice, communication, and/or auditory processing disorder, group, 2 or more individuals”; “(Do not report 92508 in conjunction with 97154, 97158)”; “Untimed”. The table lists 92508 with “Untimed” under Time to Report.
  5. American Speech-Language-Hearing Association. Speech-Language Pathology Treatment Codes Replacing 92507. Checked October 23, 2026.
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    “Key Dates: CPT code 92507 remains in effect through December 31, 2026. The new codes take effect January 1, 2027.”; “The new codes describe individual treatment by clinical service and use a time-based structure consisting of a base and add-on codes.”; “Other payers may decide if and when to implement the new codes into their fee schedules.”
  6. UnitedHealthcare. Habilitation and Rehabilitation Therapy (Occupational, Physical, and Speech) (Commercial and Individual Exchange Medical Policy MP.026.27, effective July 1, 2026; Group Therapy documentation). Checked October 23, 2026.
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    “Prescribing provider’s order for group therapy; and”; “Individualized treatment plan that includes frequency and duration of the prescribed group therapy and individualized treatment goals; and”; “Name and signature of licensed therapist providing supervision over the group therapy session; and”; “Specific treatment techniques used during the group therapy session and how the techniques will restore function;”; “Accurate documentation of the length of treatment session; and”; “Group therapy setting or location; and”; “Number of clients in the group”.
  7. Texas Medicaid & Healthcare Partnership. Texas Medicaid Provider Procedures Manual, Physical Therapy, Occupational Therapy, and Speech Therapy Services Handbook (October 2026; sections 4.5.1 and 4.5.1.1, and the PT and OT treatment procedure codes). Checked October 23, 2026.
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    “Prescribing provider’s prescription for group therapy.”; “The licensed therapist involved in group therapy services must be in constant attendance (in the same room) and active in the therapy.”; “Each client participating in the group must have an individualized treatment plan for group treatment, including interventions and short-and long-term goals and measurable outcomes.”; “Start and stop times for each session.”; “Texas Medicaid does not limit the number of clients who can participate in a group therapy session.”; “Providers are subject to certification and licensure board standards regarding group therapy.”; “For clients who are 20 years of age and younger, when physical or occupational group therapy is administered, providers can bill procedure code 97150 for each member of the group.”
  8. U.S. Department of Health and Human Services, Office for Civil Rights. May mental health practitioners or other specialists provide therapy to patients in a group setting where other patients and family members are present? (HIPAA FAQ; content last reviewed January 9, 2023). Checked October 23, 2026.
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    “Disclosures of protected health information in a group therapy setting are treatment disclosures and, thus, may be made without an individual’s authorization.”; “the HIPAA Privacy Rule generally permits a covered entity to disclose protected health information to a family member or other person involved in the individual’s care.”; “Absent countervailing circumstances, the individual’s agreement to participate in group therapy or family discussions is a good basis for inferring the individual’s agreement.”
  9. U.S. Department of Health and Human Services. Covered Entities and Business Associates (content last reviewed August 21, 2024). “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.” Checked October 23, 2026.
  10. eCFR. 42 CFR 410.60 Outpatient physical therapy services: Conditions (paragraphs (a)(4) and (c)(2)). “Claims for services furnished in whole or in part by a physical therapist assistant must include the prescribed modifier”; “Physical therapy services may be performed by a physical therapist assistant under the general supervision of the physical therapist in private practice”. Checked October 23, 2026.
  11. eCFR. 42 CFR 410.59 Outpatient occupational therapy services: Conditions (paragraph (c)(2)). “Occupational therapy services may be performed by an occupational therapy assistant under the general supervision of the occupational therapist in private practice”. Checked October 23, 2026.
  12. American Physical Therapy Association. Supervision and Teamwork. “You should review information on state licensure and practice acts, as the requirements for the use of personnel vary widely from state to state.”; “Changes to Medicare in 2025 will impact requirements for PT supervision of PTAs.” Checked October 23, 2026.
  13. eCFR. 16 CFR 255.2 Consumer endorsements (FTC Guides Concerning the Use of Endorsements and Testimonials in Advertising, paragraphs (a) and (b)). Checked October 23, 2026.
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    “Consumer endorsements themselves are not competent and reliable scientific evidence.”; “An advertisement containing an endorsement relating the experience of one or more consumers on a central or key attribute of the product will likely be interpreted as representing that the endorser’s experience is representative of what consumers will generally achieve with the advertised product in actual, albeit variable, conditions of use.”
  14. eCFR. 16 CFR Part 465, Use of Consumer Reviews and Testimonials (section 465.4). Checked October 23, 2026.
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    “It is an unfair or deceptive act or practice and a violation of this part for a business to provide compensation or other incentives in exchange for, or conditioned expressly or by implication on, the writing or creation of consumer reviews expressing a particular sentiment, whether positive or negative, regarding the product, service, or business that is the subject of the review.”
  15. Academy of Pediatric Physical Therapy, APTA. Fact Sheet: Fitness, Wellness, Health Promotion, and Prevention: The Role and Scope of Pediatric Physical Therapy (2012). Checked October 23, 2026.
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    “defines scope of practice to include a role in prevention, health promotion, wellness, fitness and screening activities”; “As the Guide recommends, once the physical therapy goals have been achieved, physical therapists refer patients to other health practitioners (e.g., community fitness staff) for health promotion and long-term fitness and well-ness programs.”; “Reimbursement will differ depending on the family’s insurance, the setting for the physical therapy (e.g., clinic, school, early intervention) and the type of intervention (e.g., primary, secondary, tertiary).”
  16. American Speech-Language-Hearing Association. Social Communication Disorder (Practice Portal). Checked October 23, 2026.
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    “Group interventions are used in conjunction with one-on-one services to practice skills in functional communication settings and to promote generalization.”; “Groups typically consist of two to eight individuals with SCD and a teacher or an adult facilitator. Social skills groups can be used across a wide range of ages, including school-age children and adults.”; “Intervention and supports for adults with social communication needs may be available in various forms (e.g., social skills groups, conversation groups, life skills groups, and workshops) and from a variety of providers (e.g., SLPs, psychologists, college counselors, and vocational counselors).”
  17. Clemson L, Cumming RG, Kendig H, et al. The effectiveness of a community-based program for reducing the incidence of falls in the elderly: a randomized trial (J Am Geriatr Soc. 2004;52(9):1487-94; doi:10.1111/j.1532-5415.2004.52411.x; PMID 15341550; abstract). Checked October 23, 2026.
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    “To test whether Stepping On, a multifaceted community-based program using a small-group learning environment, is effective in reducing falls in at-risk people living at home.”; “Three hundred ten community residents aged 70 and older who had had a fall in the previous 12 months or were concerned about falling.”; “Two-hour sessions were conducted weekly for 7 weeks, with a follow-up occupational therapy home visit.”; “The intervention group experienced a 31% reduction in falls”.
  18. American Speech-Language-Hearing Association. Aphasia (Practice Portal). “For example, in addition to one-on-one treatment, group treatment is often used to apply learned strategies in a more natural conversational context.”; “Community aphasia groups can help support work that is done within the clinical setting.” Checked October 23, 2026.
  19. Cahill SM, Beisbier S. Occupational Therapy Practice Guidelines for Children and Youth Ages 5-21 Years (Am J Occup Ther. 2020;74(4):7404397010; doi:10.5014/ajot.2020.744001; PMID 32602457; abstract). Checked October 23, 2026.
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    “The results from three systematic reviews (SRs) of activity- and occupation-based interventions for children and youth ages 5-21 yr were reviewed, synthesized, and translated into recommendations for education, practice, and research.”; “The evidence also supports group service models and models that include peer mediation; these models can promote participation across areas of occupation.”; “Skills-based training and therapeutic practice in the context of valued occupations are recommended over isolated sensorimotor approaches.”
  20. American Occupational Therapy Association. Practice Smart! (AOTA’s recommendations, formerly published through Choosing Wisely). Checked October 23, 2026.
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    “Don’t provide intervention activities that are non-purposeful (e.g., cones, pegs, shoulder arc, arm bike).”; “Don’t provide sensory-based interventions to individual children or youth without documented assessment results of difficulties processing or integrating sensory information.”; “Don’t initiate occupational therapy interventions without completion of the client’s occupational profile and setting collaborative goals.”
  21. Reichow B, Steiner AM, Volkmar F. Social skills groups for people aged 6 to 21 with autism spectrum disorders (ASD) (Cochrane Database Syst Rev. 2012;(7):CD008511; doi:10.1002/14651858.CD008511.pub2; PMID 22786515; abstract). Checked October 23, 2026.
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    “We included five RCTs evaluating the effects of social skills groups in 196 participants with ASD aged 6 to 21 years old.”; “The results show there is some evidence that social skills groups improve overall social competence”; “friendship quality (ES = 0.41, 95% CI 0.02 to 0.81, P = 0.04) for this population”; “The control group could be no intervention, wait list, or treatment as usual.”; “Given the nature of the intervention and the selected outcome measures, the risk of performance and detection bias are high.”; “they focused mainly on children aged 7 to 12, and the participants were all of average or above average intelligence.”
  22. Gates JA, Kang E, Lerner MD. Efficacy of group social skills interventions for youth with autism spectrum disorder: A systematic review and meta-analysis (Clin Psychol Rev. 2017;52:164-181; doi:10.1016/j.cpr.2017.01.006; PMID 28130983; abstract). Checked October 23, 2026.
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    “Nineteen RCTs met inclusion criteria.”; “Results show that overall positive aggregate effects were medium”; “Social skills interventions presently appear modestly effective for youth with ASD, but may not generalize to school settings or self-reported social behavior.”
  23. Lanyon LE, Rose ML, Worrall L. The efficacy of outpatient and community-based aphasia group interventions: a systematic review (Int J Speech Lang Pathol. 2013;15(4):359-74; doi:10.3109/17549507.2012.752865; PMID 23336826; abstract). Checked October 23, 2026.
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    “29 studies met inclusion and exclusion criteria.”; “Overall, the results indicate that community and outpatient group participation can improve specific linguistic processes.”; “However, there is limited evidence demonstrating improvement in functional communication as a consequence of group participation.”
  24. English C, Hillier SL, Lynch EA. Circuit class therapy for improving mobility after stroke (Cochrane Database Syst Rev. 2017;6(6):CD007513; doi:10.1002/14651858.CD007513.pub3; PMID 28573757; abstract). Checked October 23, 2026.
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    “Circuit class therapy (CCT) offers a supervised group forum for people after stroke to practise tasks, enabling increased practice time without increasing staffing.”; “We included 17 RCTs involving 1297 participants.”; “demonstrating that CCT was superior to the comparison intervention”; “There is moderate evidence that CCT is effective in improving mobility for people after stroke - they may be able to walk further, faster, with more independence and confidence in their balance.”; “The potential risk of increased falls during CCT needs to be monitored.”
  25. Sherrington C, Fairhall NJ, Wallbank GK, et al. Exercise for preventing falls in older people living in the community (Cochrane Database Syst Rev. 2019;1(1):CD012424; doi:10.1002/14651858.CD012424.pub2; PMID 30703272; abstract). Checked October 23, 2026.
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    “We included randomised controlled trials (RCTs) evaluating the effects of any form of exercise as a single intervention on falls in people aged 60+ years living in the community.”; “We included 108 RCTs with 23,407 participants living in the community in 25 countries.”; “Compared with control, balance and functional exercises reduce the rate of falls by 24% (RaR 0.76, 95% CI 0.70 to 0.81; 7920 participants, 39 studies; high-certainty evidence)”; “Exercise programmes that reduce falls primarily involve balance and functional exercises”.
  26. Fragala-Pinkham MA, Haley SM, Goodgold S. Evaluation of a community-based group fitness program for children with disabilities (Pediatr Phys Ther. 2006;18(2):159-67; doi:10.1097/01.pep.0000223093.28098.12; PMID 16735864; abstract). Checked October 23, 2026.
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    “Twenty-eight children with neuromuscular and developmental disabilities, 6 to 14 years of age, participated.”; “A pretest-posttest design was used”; “Mean program attendance was 75.3%, and no injuries were reported.”; “Physical therapists partnering with community centers may feasibly and safely shift group fitness programs for school-aged children with disabilities from the medical setting to the community.”
  27. Allen KD, Bongiorni D, Bosworth HB, et al. Group Versus Individual Physical Therapy for Veterans With Knee Osteoarthritis: Randomized Clinical Trial (Phys Ther. 2016;96(5):597-608; doi:10.2522/ptj.20150194; PMID 26586865; abstract). Checked October 23, 2026.
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    “Three hundred twenty patients with knee OA”; “group physical therapy; six 1-hour sessions, typically 8 participants per group”; “individual physical therapy; two 1-hour sessions”; “Group physical therapy was not more effective than individual physical therapy for primary and secondary study outcomes.”
  28. American Physical Therapy Association. Coding Interpretations: Group Therapy Patient Scenarios (article dated November 13, 2018; public introduction). “Concerns have been raised regarding the delivery of outpatient physical therapy services, specifically regarding the appropriate use of one-on-one codes as opposed to the group code.” Checked October 23, 2026.
  29. Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual, Chapter 5, Part B Outpatient Rehabilitation and CORF/OPT Services (section 20.2, Reporting of Service Units With HCPCS). Checked October 23, 2026.
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    “When reporting service units for HCPCS codes where the procedure is not defined by a specific timeframe (“untimed” HCPCS), the provider enters “1” in the field labeled units.”; “For any single timed CPT code in the same day measured in 15 minute units, providers bill a single 15-minute unit for treatment greater than or equal to 8 minutes through and including 22 minutes.”
  30. Centers for Medicare & Medicaid Services. Patient Driven Payment Model Fact Sheet: Concurrent and Group Therapy Limit (PDF in the ZIP linked from the CMS Patient Driven Payment Model page; last revised February 14, 2019). Checked October 23, 2026.
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    “Individual services are provided by one therapist or assistant to one resident at a time.”; “Concurrent therapy is defined as the treatment of 2 residents at the same time, when the residents are not performing the same or similar activities, regardless of payer source, both of whom must be in line-of-sight of the treating therapist or assistant for Medicare Part A.”; “Group therapy is defined for Part A as the treatment of 2-6 residents, regardless of payer source, who are performing the same or similar activities, and are supervised by a therapist or an assistant who is not supervising any other individuals.”; “In order to mitigate this potential effect of PDPM, CMS imposed a limit of 25 percent on concurrent and group therapy.”; “CMS grouping software will calculate the percentage of group and concurrent therapy, combined, provided to each patient, by discipline, as a percentage of all therapies provided to that patient.”; “There will be no penalty for exceeding the 25% combined concurrent and group therapy limit.”; “providers will receive a warning edit on their assessment validation report”.
  31. American Physical Therapy Association. When to Use Group Therapy Under the Patient-Driven Payment Model (article dated January 1, 2020; public introduction). Checked October 23, 2026.
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    “The Patient-Driven Payment Model restricts use of group and concurrent therapy, limiting these services to no more than 25% of a resident’s total therapy minutes.”; “Hearing that some SNFs have incorrectly used this provision to mandate 25% group therapy”.
  32. American Speech-Language-Hearing Association. Medicare Coding Rules for Speech-Language Pathology Services (Reimbursement, Medicare; including its quotation of the NCCI Policy Manual, Chapter 11, Section H-2). Checked October 23, 2026.
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    “Speech language pathologists may perform services coded as CPT codes 92507, 92508, or 92526. They do not perform services coded as CPT codes 97110, 97112, 97150, or 97530, which are generally performed by physical or occupational therapists.”; “Generally, CMS won’t pay for this code when reported by an SLP. However, some MACs may allow SLPs to report 97150 for group therapy for conditions not covered under 92508, such as cognition or dysphagia.”; “Group caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community”; “(without the patient present), face to face with multiple sets of caregivers”; “New in 2024.”
  33. Medicaid.gov. Mandatory & Optional Medicaid Benefits (Physical therapy, occupational therapy and speech, hearing and language disorder services are listed under Optional Benefits). Checked October 23, 2026.
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    “States may provide optional benefits if they choose to add them through the state plan process.”; “Physical therapy (1905(a)(11), 42 CFR 440.110(a))”; “Occupational therapy (1905(a)(11), 42 CFR 440.110(b))”; “Speech, hearing and language disorder services (1905(a)(11), 42 CFR 440.110(c))”.
  34. Medicaid.gov. Early and Periodic Screening, Diagnostic, and Treatment. “provides comprehensive and preventive health care services for children under age 21 who are enrolled in Medicaid”; “It is the responsibility of states to determine medical necessity on a case-by-case basis.” Checked October 23, 2026.
  35. Centers for Medicare & Medicaid Services. What is a good faith health insurance estimate? (Medical bill rights; page last modified October 5, 2026). Checked October 23, 2026.
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    “Usually, if you aren’t using health insurance to pay for your care, your health care provider must give you a good faith estimate of expected charges if you request one or schedule services at least 3 business days in advance.”
  36. American Speech-Language-Hearing Association. Code of Ethics (effective March 1, 2023). Checked October 23, 2026.
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    “they shall inform those they serve professionally of the name, role, and professional credentials of persons providing services.”; “Individuals shall obtain informed consent from the persons they serve about the nature and possible risks and effects of services provided, technology employed, and products dispensed.”; “If diminished decision-making ability of persons served is suspected, individuals should seek appropriate authorization for services, such as authorization from a legally authorized/appointed representative.”; “they shall provide services or dispense products only when benefit can reasonably be expected.”; “Individuals may make a reasonable statement of prognosis, but they shall not guarantee—directly or by implication—the results of any treatment or procedure.”; “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.”
  37. American Physical Therapy Association. Code of Ethics for the Physical Therapist (HOD S06-20-28-25, last updated August 12, 2020). Checked October 23, 2026.
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    “2C. Physical therapists shall provide the information necessary to allow patients or their surrogates to make informed decisions about physical therapist care or participation in clinical research.”; “4A. Physical therapists shall provide truthful, accurate, and relevant information and shall not make misleading representations.”; “8C. Physical therapists shall be responsible stewards of health care resources and shall avoid overutilization or under- utilization of physical therapist services.”; “7E. Physical therapists shall be aware of charges and shall ensure that documentation and coding for physical therapist services accurately reflect the nature and extent of the services provided.”
  38. American Occupational Therapy Association. Ethics (Practice Essentials; the page links the AOTA 2025 Occupational Therapy Code of Ethics, doi:10.5014/ajot.2025.79S302). Checked October 23, 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’s Code of Ethics Core Values and Principles infographic (© 2025) names autonomy and veracity among the guiding ethical principles and states that “Sanctionable offenses and violations of ethical standards are addressed separately under the Code’s Standards of Conduct, which outline specific and enforceable behaviors.”
  39. U.S. Department of Health and Human Services, Office for Civil Rights. Personal Representatives (HIPAA Privacy Rule guidance; content last reviewed January 5, 2024). Checked October 23, 2026.
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    “In most cases under the Rule, a parent, guardian, or other person acting in loco parentis (collectively, “parent”) is the personal representative of the minor child and can exercise the minor’s rights with respect to protected health information, because the parent usually has the authority to make health care decisions about his or her minor child.”; “These exceptions generally track the ability of certain minors to obtain specified health care without parental consent under State or other laws, or standards of professional practice.”
  40. U.S. Department of Health and Human Services, Office for Civil Rights. Incidental Uses and Disclosures (HIPAA Privacy Rule guidance; content last reviewed July 26, 2013). Checked October 23, 2026.
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    “the Privacy Rule permits certain incidental uses and disclosures of protected health information to occur when the covered entity has in place reasonable safeguards and minimum necessary policies and procedures to protect an individual’s privacy.”; “By speaking quietly when discussing a patient’s condition with family members in a waiting room or other public area;”; “An incidental use or disclosure that occurs as a result of a failure to apply reasonable safeguards or the minimum necessary standard, where required, is not permitted under the Privacy Rule.”
  41. U.S. Department of Health and Human Services, Office for Civil Rights. May physician’s offices use patient sign-in sheets or call out the names of their patients in their waiting rooms? (HIPAA FAQ; content last reviewed December 28, 2022). Checked October 23, 2026.
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    “For example, the sign-in sheet may not display medical information that is not necessary for the purpose of signing in (e.g., the medical problem for which the patient is seeing the physician).”
  42. U.S. Department of Health and Human Services, Office for Civil Rights. Marketing (HIPAA Privacy Rule guidance; content last reviewed July 26, 2013). Checked October 23, 2026.
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    “This exception to the marketing definition permits communications by a covered entity about its own products or services.”; “A hospital uses its patient list to announce the arrival of a new specialty group (e.g., orthopedic) or the acquisition of new equipment (e.g., x-ray machine or magnetic resonance image machine) through a general mailing or publication.”
  43. eCFR. 45 CFR 164.508 Uses and disclosures for which an authorization is required (paragraph (a)(1)). “Except as otherwise permitted or required by this subchapter, a covered entity may not use or disclose protected health information without an authorization that is valid under this section.” Checked October 23, 2026.
  44. eCFR. 28 CFR 36.301 Eligibility criteria (ADA Title III regulations, paragraphs (a) and (c)). Checked October 23, 2026.
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    “A public accommodation shall not impose or apply eligibility criteria that screen out or tend to screen out an individual with a disability or any class of individuals with disabilities from fully and equally enjoying any goods, services, facilities, privileges, advantages, or accommodations, unless such criteria can be shown to be necessary for the provision of the goods, services, facilities, privileges, advantages, or accommodations being offered.”; “A public accommodation may not impose a surcharge on a particular individual with a disability or any group of individuals with disabilities to cover the costs of measures, such as the provision of auxiliary aids”.
  45. eCFR. 28 CFR 36.302 Modifications in policies, practices, or procedures (ADA Title III regulations, paragraph (a)). Checked October 23, 2026.
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    “A public accommodation shall make reasonable modifications in policies, practices, or procedures, when the modifications are necessary to afford goods, services, facilities, privileges, advantages, or accommodations to individuals with disabilities, unless the public accommodation can demonstrate that making the modifications would fundamentally alter the nature of the goods, services, facilities, privileges, advantages, or accommodations.”
  46. U.S. Department of Justice, Civil Rights Division, ADA.gov. ADA Requirements: Effective Communication (last updated February 28, 2020). Checked October 23, 2026.
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    “The ADA requires that title II entities (State and local governments) and title III entities (businesses and nonprofit organizations that serve the public) communicate effectively with people who have communication disabilities.”; “The key to communicating effectively is to consider the nature, length, complexity, and context of the communication and the person’s normal method(s) of communication.”; “They cannot require a person to bring someone to interpret for him or her.”
  47. Centers for Medicare & Medicaid Services. Therapy Services (page last modified March 10, 2026). Checked October 23, 2026.
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    “Section 53107 of the BBA of 2018 additionally requires CMS, using a new modifier, to make payment at a reduced rate for physical therapy and occupational therapy services that are furnished in whole or in part by physical therapist assistants (PTAs) and occupational therapy assistants (OTAs).”; “Payment for these services is at 85 percent of the otherwise applicable PFS payment amount/rate for the service, effective January 1, 2022.”
  48. American Speech-Language-Hearing Association. Speech-Language Pathology Assistants (Practice Portal). “Regulations for speech-language pathology support personnel in educational and other practice settings vary from state to state. Differences may be reflected in a number of requirements, including education, supervision, continuing education, titles used for support personnel, or the lack of regulation or laws.” Checked October 23, 2026.
  49. Federal Trade Commission. Advertising FAQ’s: A Guide for Small Business (FTC business guidance). “Advertising must be truthful and non-deceptive;”; “Advertisers must have evidence to back up their claims; and”; “Statements from satisfied customers usually are not sufficient to support a health or safety claim or any other claim that requires objective evaluation.” Checked October 23, 2026.
  50. Federal Trade Commission. Health Products Compliance Guidance (FTC staff guidance, December 2022). “the same legal principles apply to the marketing of any health-related product”; “Section 12 prohibits the dissemination of false advertisements for foods, drugs, devices, services, or cosmetics”; “clearly explain the limited circumstances in which the advertised benefits or results apply”. Checked October 23, 2026.
  51. eCFR. 16 CFR 255.5 Disclosure of material connections (paragraph (a)). Checked October 23, 2026.
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    “When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement, and that connection is not reasonably expected by the audience, such connection must be disclosed clearly and conspicuously.”; “They can include monetary payment or the provision of free or discounted products (including products unrelated to the endorsed product) to an endorser, regardless of whether the advertiser requires an endorsement in return.”
  52. HHS Office of Inspector General. Policy Statement Regarding Gifts of Nominal Value To Medicare and Medicaid Beneficiaries (December 7, 2016). Checked October 23, 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”; “a retail value of no more than $15 per item or $75 in the aggregate per patient on an annual basis”; “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).”

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. Group rules differ by payer, Medicare contractor and state, and its examples are hypothetical, not DrSensory data or clinical benchmarks.