September 18, 2019
Pathway for Independent Physical Therapy Practice at Hospital Outpatient Facilities
In 2018, the Illinois Physical Therapy Practice Act was changed to allow physical therapists to provide physical therapy (PT) services without a referral from a healthcare professional. IHA has learned that some members would like to utilize this new provision to allow for the independent practice of physical therapists at their outpatient facilities licensed under the hospital, however they feel it is prohibitive under current hospital licensing regulations.
IHA legal counsel has reviewed the current regulations and have determined, with the concurrence of the Illinois Department of Public Health’s (IDPH’s) legal staff and the Hospital Licensing Board, that there is an avenue for hospitals to permit independent physical therapy practice in the outpatient setting, if they so choose.
Section 250.330(e) of the Hospital Licensing Requirements creates an exception to the requirement of an order from a member of the medical staff:
The medical director of the physical therapy or rehabilitation department may authorize the provision of physical therapy or rehabilitation services or treatments at the request of other than members of the medical staff in accordance with policies approved by the medical staff and governing board.
Since there is no definition or limitation to “other than members of the medical staff,” the person requesting services could be the patient, assuming it is “in accordance with policies approved by the medical staff and governing board.” Hospitals seeking to provide these services must make the appropriate changes to their policies.
As stated, this interpretation by IHA legal counsel has been discussed and approved by both IDPH and the Hospital Licensing Board. Members should note the following:
- IDPH believes this is limited to PT services provided in the outpatient setting. Appropriate referrals are still necessary for patients admitted to the hospital; and
- While this is a pathway to allow the independent practice of physical therapists in the hospital outpatient setting, it does not require hospitals to implement such policies if they do not wish to do so.