CTfJ. Hardin-Sim Jniversity Department of,.j~ical Therapy. Proposed OPT CurriCUlum By Semester. Total Curriculum Credit Hours:

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1 Hardin-Sim Jniversity Department of,.j~ical Therapy Proposed OPT CurriCUlum By Semester Total Curriculum Credit Hours: Number Course Title Hrs Credit Number Course Title Hrs Credit 7401 Clinical Anatomy I Clinical Anatomy II Applied Physiology I Applied Physiology II Clinical Kinesiology I Clinical Kinesiology II Introduction to Clinical Diagnosis & Management I Introduction to Clinical Diagnosis & Management II Professional Seminar I Critical Inquiry II Critical Inquiry I Neuroscience I Orientation to the Physical Therapy Profession 7232 DiagnostiC Screening, Imaging & Pharmacology I 2 Number Course Title Hrs Credit Number Course Title Hrs Credit 7233 Diagnostic Screening, Imaging & Pharmacology Professional Project II Clinical Diagnosis & Management I: Musculoskeletal I Neuroscience II Clinical Diagnosis & Management II: Cardiovascular & Pulmonary Clinical Diagnosis & Management IV: Musculoskeletal Professional Project I Clinical Diagnosis & Management V: Neurological Clinical Diagnosis & Management III: Neurological I Clinical Diagnosis & Management VI: Integumentary Experiential Professional Activity I Clinical Diagnosis & Management VII: Pediatrics & Geriatri Professional Seminar II 2 CTfJ Number Course Title Hrs Credit Number Course Title Hrs Credit 7230 Clinical Diagnosis & Management VIII: Multiple Systems Experiential Professional Activity III Experiential Professional Activity II Experiential Professional Activity IV Professional Project III 7428 Healthcare Management Professional Seminar III Critical Inquiry III Experiential Professional Activity Campus Clinic Number Course Title Hrs Credit 7775 Experiential Professional Activity V Experiential Professional Activity VI Professional Seminar IV 7102 Professional Development 6f712012

2 HARDIN*SIMMONS UN I V E R SIT Y Faculty Contact Information Dr. Jacob Brewer jbrewer@hsutx.edu Dr. Robert Friberg rfriberg@hsutx.edu Mary Lou Garrett, PT, DPT rngarrett@hsutx.edu Dr. Dennis O'Connell oconnell@hsutx.edu Dr. Janelle O'Connell joconnel@hsutx.edu Dr. Marty Hinman rnhinrnan@hsutx.edu Dr. Marsha Rutland rnrutland@hsutx.edu For immediate assistance, contact the PT office: ptoffice@hsutx.edu

3 Professionalism & Core Values Core Values APTA has identified seven that define the critical elements of professionalism in physical therapy. These core values are listed below in alphabetical order with no preference or ranking given to these values. The seven values identified were of sufficient breadth and depth to incorporate the many values and attributes that are part of physical therapist professionalism. For each core value listed, the list that follows explicates these values by providing a core value definition and sample indicators (not exhaustive) that describe what the physical therapist would be doing in practice, education, and/or research if these core values were present. o o o o o o o Accountability Altruism Compassion/Caring Excellence Integrity Professional Duty Social Responsibility Accountability Accountability is active acceptance of the responsibility for the diverse roles, obligations, and actions of the physical therapist including self-regulation and other behaviors that positively influence patient/client outcomes, the profession and the health needs of society. 1. Responding to patients/client's goals and needs. 2. Seeking and responding to feedback from multiple sources. 3. Acknowledging and accepting consequences of his/her actions. 4. Assuming responsibility for learning and change. 5. Adhering to code of ethics, standards of practice, and policies/procedures that govern the conduct of professional activities. 6. Communicating accurately to others (payers, patients/clients, other health care providers) about professional actions. 7. Participating in the achievement of health goals of patients/clients and society. 8. Seeking continuous improvement in quality of care. 9. Maintaining membership in APTA and other organizations. 10. Educating students in a manner that facilitates the pursuit of learning.

4 Altruism Altruism is the primary regard for or devotion to the interest of patients/clients, thus assuming the fiduciary responsibility of placing the needs of the patient/client ahead of the physical therapist's self- interest. 1. Placing patient's/client s needs above the physical therapists. 2. Providing pro bono services. 3. Providing physical therapy services to underserved and underrepresented populations. 4. Providing patient/client services that go beyond expected standards of practice. 5. Completing patient/client care and professional responsibility prior to personal needs. Compassion/Caring Compassion is the desire to identify with or sense something of another's experience; a precursor of caring. Caring is the concern, empathy, and consideration for the needs and values of others. 1. Understanding the socio-cultural, psychological and economic influences on the individual's life in their environment. 2. Understanding an individual's perspective. 3. Being an advocate for patient's/client s needs. 4. Communicating effectively, both verbally and non-verbally, with others taking into consideration individual differences in learning styles, language, and cognitive abilities, etc. 5. Designing patient/client programs/interventions that are congruent with patient/client needs. 6. Empowering patients/clients to achieve the highest level of function possible and to exercise self-determination in their care. 7. Focusing on achieving the greatest well-being and the highest potential for a patient/client. 8. Recognizing and refraining from acting on one's social, cultural, gender, and sexual biases. 9. Embracing the patient's/client s emotional and psychological aspects of care. 10. Attending to the patient's/client s personal needs and comforts. 11. Demonstrating respect for others and considers others as unique and of value.

5 Excellence Excellence is physical therapy practice that consistently uses current knowledge and theory while understanding personal limits, integrates judgment and the patient/client perspective, embraces advancement, challenges mediocrity, and works toward development of new knowledge. 1. Demonstrating investment in the profession of physical therapy. 2. Internalizing the importance of using multiple sources of evidence to support professional practice and decisions. 3. Participating in integrative and collaborative practice to promote high quality health and educational outcomes. 4. Conveying intellectual humility in professional and interpersonal situations. 5. Demonstrating high levels of knowledge and skill in all aspects of the profession. 6. Using evidence consistently to support professional decisions. 7. Demonstrating a tolerance for ambiguity. 8. Pursuing new evidence to expand knowledge. 9. Engaging in acquisition of new knowledge throughout one's professional career. 10. Sharing one's knowledge with others. 11. Contributing to the development and shaping of excellence in all professional roles. Integrity Steadfast adherence to high ethical principles or professional standards; truthfulness, fairness, doing what you say you will do, and "speaking forth" about why you do what you do. 1. Abiding by the rules, regulations, and laws applicable to the profession. 2. Adhering to the highest standards of the profession (practice, ethics, reimbursement, Institutional Review Board [IRB], honor code, etc). 3. Articulating and internalizing stated ideals and professional values. 4. Using power (including avoidance of use of unearned privilege) judiciously. 5. Resolving dilemmas with respect to a consistent set of core values. 6. Being trustworthy. 7. Taking responsibility to be an integral part in the continuing management of patients/clients. 8. Knowing one's limitations and acting accordingly. 9. Confronting harassment and bias among ourselves and others. 10. Recognizing the limits of one's expertise and making referrals appropriately. 11. Choosing employment situations that are congruent with practice values and professional ethical standards. 12. Acting on the basis of professional values even when the results of the behavior may place oneself at risk.

6 Professional Duty Professional duty is the commitment to meeting one's obligations to provide effective physical therapy services to individual patients/clients, to serve the profession, and to positively influence the health of society. 1. Demonstrating beneficence by providing "optimal care." 2. Facilitating each individual s achievement of goals for function, health, and wellness. 3. Preserving the safety, security and confidentiality of individuals in all professional contexts. 4. Involved in professional activities beyond the practice setting. 5. Promoting the profession of physical therapy. 6. Mentoring others to realize their potential. 7. Taking pride in one s profession. Social Responsibility Social responsibility is the promotion of a mutual trust between the profession and the larger public that necessitates responding to societal needs for health and wellness. 1. Advocating for the health and wellness needs of society including access to health care and physical therapy services. 2. Promoting cultural competence within the profession and the larger public. 3. Promoting social policy that effect function, health, and wellness needs of patients/clients. 4. Ensuring that existing social policy is in the best interest of the patient/client. 5. Advocating for changes in laws, regulations, standards, and guidelines that affect physical therapist service provision. 6. Promoting community volunteerism. 7. Participating in political activism. 8. Participating in achievement of societal health goals. 9. Understanding of current community wide, nationwide and worldwide issues and how they impact society s health and well-being and the delivery of physical therapy. 10. Providing leadership in the community. 11. Participating in collaborative relationships with other health practitioners and the public at large. 12. Ensuring the blending of social justice and economic efficiency of services.

7 Code of Ethics for the Physical Therapist I-lOD S [Amended HOD S ; HOD ;HOD ; ' ; HOD ; HOD ; HOD ; HOD ; Iliitiai HOD J [Standard] APTA American Physicallherapy Association_ Preamble The Code ofethics for the Physical Therapist (Code ofethics) delineates the ethical obligations ofall physical therapists as determined by the House ofdelegates ofthe American Physical Therapy Association (APTA). The purposes ofthis Code ofethics are to: 1. Define the ethical principles that form the foundation ofphysical therapist practice in patient/client management, consultation, education, research, and administration. 2. Provide standards ofbehavior and performance that form the basis ofprofessional accountabiliry to the public. 3. Provide guidance for physical therapists facing ethical challenges, regardless oftheir professional roles and responsibilities. 4. Educate physical therapists, students, other health care professionals, regularors, and the public regarding the core values, ethical principles, and standards that guide the professional conduct ofthe physical therapist. 5. Establish the standards by which the American Physical Therapy Association can determine ifa physical therapist has engaged in unethical conduct. No code ofethics is exhaustive nor can it address every situation. Physical therapists are encouraged to seek additional advice or consultation in instances where the guidance ofthe Code ofethics may not be definitive. This Code ofethics is built upon the five roles ofthe physical therapist (management ofpatients/clients, consultation, education, research, and administration), the core values ofthe profession, and the multiple realms ofethical action (individual, organizational, and societal). Physical therapist practice is guided by a set ofseven core values: accountability, altruism, compassion/caring, excellence, integriry, professional dury, and social responsibiliry. Throughour the document the primary core values that support specific principles are indicated in parentheses. Unless a specific role is indicated in the principle, the duties and obligations being delineated pertain to the five roles ofthe physical therapist. Fundamental to the Code ofethics is the special obligation ofphysical therapists to empower, educate, and enable those with impairments, activity limitations, participation restrictions, and disabilities to facilitate greater independence, health, wellness, and. hanced quality oflife. Principles Principle #1: Physical therapists shall respect the inherent dignity and rights of all individuals. (Core Values: Compassion, Integrity) la. Physical therapists shall act in a respectful manner toward each person regardless ofage, gender, race, nationality, religion, ethnicity, social or economic status, sexual orientation, health condition, or disabiliry. lb. Physical therapists shall recognize their personal biases and shall not discriminate against others in physical therapist practice, consultation, education, research, and administration. Principle #2: Physical therapists shall be trustworthy and compassionate in addressing the rights and needs of patients/clients. (Core Values: Altruism, Compassion, Professional Duty) 2A. Physical therapists shall adhere to the core values ofthe profession and shall act in the best interests ofpatients/clients over the interests ofthe physical therapist. 2B. Physical therapists shall provide physical therapy services with compassionate and caring behaviors that incorporate the individual and culrural differences ofpatients/clients. 2C. Physical therapists shall provide the information necessary to allow patients or their surrogates to make informed decisions about physical therapy care or participation in clinical research. 20. Physical therapists shall collaborate with patients/clients to empower them in decisions about their health care. 2E. Physical therapists shall protect confidential patient/ client information and may disclose confidential information to appropriate authorities only when allowed or as required by law. Principle #3: Physical therapists shall be accountable for making sound professional judgments. (Core Values: Excellence, Integrity) 3A. Physical therapists shall demonstrate independent and objective professional judgment in the patient's/client's best interest in all practice settings. 3B. Physical therapists shall demonstrate professional judgment informed by professional standards, evidence (including current literature and established best practice). practitioner experience, and patient/client values. 3C. Physical therapists shall make judgments within their scope ofpractice and level ofexpertise and shall communicate with, collaborate with, or refer to peers or other health care professionals when necessary. 3D. Physical therapists shall not engage in conflicts ofinterest that interfere with professional judgment. 3E. Physical therapists shall provide appropriate direction ofand communication with physical therapist assistants and support personnel.

8 Principle #4: Physical therapists shall demonstrate integrity in their relationships with patients/clients, families, colleagues, students, research participants, other health care providers, employers, payers, and the public. (Core Value: Integrity) 4A. Physical therapists shall provide truthful, accurate, and relevant information and shall not make misleading representations. 4B. Physical therapists shall not exploit persons over whom they have supervisory, evaluative or other authority (eg, patients! clients, students, supervisees, research participants, or employees). 4e. Physical therapists shall discourage misconduct by health care professionals and report illegal or unethical acts co the relevant authority, when appropriate. 4D. Physical therapists shall report suspected cases of abuse involving children or vulnerable adults to the appropriate authority, subject co law. 4E. Physical therapists shall not engage in any sexual relationship with any of their patients! clients, supervisees, or students. 4F. Physical therapists shall not harass anyone verbally, physically, emotionally, or sexually. Principle #5: Physical therapists shall fulfill their legal and professional obligations. (Core Values: Professional Duty, Accountability) SA. Physical therapists shall comply with applicable local, state, and federal laws and regulations. SB. Physical therapists shall have primary responsibility for supervision ofphysical therapist assistants and support personnel. Se. Physical therapists involved in research shall abide by accepted standards governing protection of research participants. SD. Physical therapists shall encourage colleagues with physical, psychological, or substance-related impairments that may adversely impact their professional responsibilities to seek assistance or counsel. SE. Physical therapists who have knowledge that a colleague is unable to perform their professional responsibilities with reasonable skill and safety shall report this information to the appropriate authority. SF. Physical therapists shall provide notice and information about alternatives for obtaining care in the event the physical therapist terminates the provider relationship while the patient! client continues to need physical therapy services. Principle #6: Physical therapists shall enhance their expertise through the lifelong acquisition and refinement of knowledge, skills, abilities, and professional behaviors. (Core Value: Excellence) 6B. Physical therapists shall take responsibility for their professional development based on critical self-assessment and reflection on changes in physical therapist practice, education, health care delivery, and technology. 6e. Physical therapists shall evaluate the strength ofevidence and applicability ofcontent presented during professional development activities before integrating the content or techniques into practice. 6D. Physical therapists shall cultivate practice environments that support professional development, lifelong learning, and excellence. Principle #7: Physical therapists shall promote organizational behaviors and business practices that benefit patients/clients and society. (Core Values: Integrity, Accountability) 7 A. Physical therapists shall promote practice environments that support autonomous and accountable professional judgments. 7B. Physical therapists shall seek remuneration as is deserved and reasonable for physical therapist services. 7e. Physical therapists shall not accept gifts or other considerations that influence or give an appearance of influencing their professional judgment. 7D. Physical therapists shall fully disclose any financial interest they have in products or services that they recommend to patients! clients. 7E. Physical therapists shall be aware ofcharges and shall ensure that documentation and coding for physical therapy services accurately reflect the nature and extent ofthe services provided. 7F. Physical therapists shall refrain from employment arrangements, or other arrangements, that prevent physical therapists from fulfilling professional obligations to patients! clients. Principle #8: Physical therapists shall participate in efforts to meet the health needs of people locally, nationally, or globally. (Core Value: Social Responsibility) 8A. Physical therapists shall provide pro bono physical therapy services or support organizations that meet the health needs ofpeople who are economically disadvantaged. uninsured, and underinsured. 8B. Physical therapists shall advocate to reduce health disparities and health care inequities, improve access to health care services, and address the health, wellness, and preventive health care needs ofpeople. 8e. Physical therapists shall be responsible stewards of health care resources and shall avoid overutilization or underutilization of physical therapy services. SD. Physical therapists shall educate members of the public about the benefits of physical therapy and the unique role ofthe physical therapist. 6A. Physical therapists shall achieve and maintain professional competence.

9 APTA American Physical Therapy Association APTA Guide for Professional Conduct Purpose This Guide for Professional Conduct (Guide) is intended to serve physical therapists in interpreting the Code of Ethics for the Physical Therapist (Code) ofthe American Physical Therapy Association (APTA) in matters of professional conduct. The APTA House of Delegates in June of 2009 adopted a revised Code, which became effective on July 1, The Guide provides a framework by which physical therapists may determine the propriety of their conduct. It is also intended to guide the professional development of physical therapist students. The Code and the Guide apply to all physical therapists. These guidelines are subject to change as the dynamics of the profession change and as new patterns of health care delivery are developed and accepted by the professional community and the public. Interpreting Ethical Principles The interpretations expressed in this Guide reflect the opinions, decisions, and advice of the Ethics and Judicial Committee (EJC). The interpretations are set forth according to topic. These interpretations are intended to assist a physical therapist in applying general ethical principles to specific situations. They address some but not all topics addressed in the Principles and should not be considered inclusive ofall situations that could evolve. This Guide is subject to change, and the Ethics and Judicial Committee will monitor and timely revise the Guide to address additional topics and Principles when necessary and as needed. The Preamble states as follows: Preamble to the Code The Code of Ethics for the Physical Therapist (Code ofethics) delineates the ethical obligations of all physical therapists as determined by the House of Delegates of the American Physical Therapy Association (APT A). The purposes ofthis Code of Ethics are to: 1. Define the ethical principles that form the foundation of physical therapist practice in patient/client management, consultation, education, research, and administration. 2. Provide standards of behavior and performance that form the basis of professional accountability to the public.

10 2 3. Provide guidance for physical therapists facing ethical challenges, regardless of their professional roles and responsibilities. 4. Educate physical therapists, students, other health care professionals, regulators, and the public regarding the core values, ethical principles, and standards that guide the professional conduct ofthe physical therapist. 5. Establish the standards by which the American Physical Therapy Association can detennine if a physical therapist has engaged in unethical conduct. No code of ethics is exhaustive nor can it address every situation. Physical therapists are encouraged to seek additional advice or consultation in instances where the guidance of the Code of Ethics may not be definitive. This Code of Ethics is built upon the five roles ofthe physical therapist (management ofpatients/clients, consultation, education, research, and administration), the core values ofthe profession, and the multiple realms of ethical action (individual, organizational, and societal). Physical therapist practice is guided by a set of seven core values: accountability, altruism, compassion/caring, excellence, integrity, professional duty, and social responsibility. Throughout the document the primary core values that support specific principles are indicated in parentheses. Unless a specific role is indicated in the principle, the duties and obligations being delineated pertain to the five roles of the physical therapist. Fundamental to the Code of Ethics is the special obligation ofphysical therapists to empower, educate, and enable those with impainnents, activity limitations, participation restrictions, and disabilities to facilitate greater independence, health, wellness, and enhanced quality oflife. Interpretation: Upon the Code of Ethics for the Physical Therapist being amended effective July 1, 2010, all the lettered principles in the Code contain the word "shall" and are mandatory ethical obligations. The language contained in the Code is intended to better explain and further clarify existing ethical obligations. These ethical obligations predate the revised Code. Although various words have changed, many of the obligations are the same. Consequently, the addition of the word "shall" serves to reinforce and clarify existing ethical obligations. A significant reason that the Code was revised was to provide physical therapists with a document that was clear enough such that they can read it standing alone without the need to seek extensive additional interpretation. The Preamble states that "[n]o Code of Ethics is exhaustive nor can it address every situation." The Preamble also states that physical therapists "are encouraged to seek additional advice or consultation in instances in which the guidance of the Code may not be definitive." Potential sources for advice and counsel include third parties and the myriad resources available on the APTA Web site. Inherent in a physical therapist's ethical decision-making process is the examination ofhis or her unique set offacts relative to the Code.

11 3 Topics Respect Principle la states as follows: IA. Physical therapists shall act in a respectful manner toward each person regardless of age, gender, race, nationality, religion, ethnicity, social or economic status, sexual orientation, health condition, or disability. Interpretation: Principle IA addresses the display of respect toward others. Unfortunately, there is no universal consensus about what respect looks like in every situation. For example, direct eye contact is viewed as respectful and courteous in some cultures and inappropriate in others. It is up to the individual to assess the appropriateness of behavior in various situations. Altruism Principle 2A states as follows: 2A Physical therapists shall adhere to the core values of the profession and shall act in the best interests of patients/clients over the interests ofthe physical therapist. Interpretation: Principle 2A reminds physical therapists to adhere to the profession's core values and act in the best interest ofpatients/clients over the interests ofthe physical therapist. Often this is done without thought, but sometimes, especially at the end ofthe day when the physical therapist is fatigued and ready to go home, it is a conscious decision. For example, the physical therapist may need to make a decision between leaving on time and staying at work longer to see a patient who was 15 minutes late for an appointment.

12 4 Patient Autonomy Principle 2C states as follows: 2C. Physical therapists shall provide the information necessary to allow patients or their surrogates to make informed decisions about physical therapy care or participation in clinical research. Interpretation: The underlying purpose of Principle 2C is to require a physical therapist to respect patient autonomy. In order to do so, a physical therapist shall communicate to the patient/client the findings ofhislher examination, evaluation, diagnosis, and prognosis. A physical therapist shall use sound professional judgment in informing the patient/client of any substantial risks ofthe recommended examination and intervention and shall collaborate with the patient/client to establish the goals oftreatment and the plan of care. Ultimately, a physical therapist shall respect the patient's/client's right to make decisions regarding the recommended plan ofcare, including consent, modification, or refusal. Professional Judgment Principles 3, 3A, and 3B state as follows: 3: Physical therapists shall be accountable for making sound professional judgments. (Core Values: Excellence, Integrity) 3A. Physical therapists shall demonstrate independent and objective professional judgment in the patient's/client's best interest in all practice settings. 3B. Physical therapists shall demonstrate professional judgment informed by professional standards, evidence (including current literature and established best practice), practitioner experience, and patient/client values. Interpretation: Principles 3, 3A, and 3B state that it is the physical therapist's obligation to exercise sound professional judgment, based upon hislher knowledge, skill, training, and experience. Principle 3B further describes the physical therapist's judgment as being informed by three elements of evidence-based practice. With regard to the patient/client management role, once a physical therapist accepts an individual for physical therapy services he/she shall be responsible for: the examination, evaluation, and diagnosis ofthat individual; the prognosis and intervention; reexamination and modification ofthe plan of care; and the maintenance of adequate records, including progress reports. A physical therapist shall establish the plan of care and shall provide and/or supervise and direct the appropriate interventions. Regardless of practice setting, a physical therapist has primary responsibility for the physical therapy care ofa patient and shall make independent judgments regarding that care consistent with accepted professional standards.

13 5 lithe diagnostic process reveals findings that are outside the scope ofthe physical therapist's knowledge, experience, or expertise or that indicate the need for care outside the scope ofphysical therapy, the physical therapist shall so infonn the patient/client and shall refer the patient/client to an appropriate practitioner. A physical therapist shall detennine when a patient/client will no longer benefit from physical therapy services. When a physical therapist's judgment is that a patient will receive negligible benefit from physical therapy services, the physical therapist shall not provide or continue to provide such services ifthe primary reason for doing so is to further the financial self-interest ofthe physical therapist or hislher employer. A physical therapist shall avoid overutilization ofphysical therapy services. See Principle Sc. Supervision Principle 3E states as follows: 3E. Physical therapists shall provide appropriate direction ofand communication with physical therapist assistants and support personnel. Interpretation: Principle 3E describes an additional circumstance in which sound professional judgment is required; namely, through the appropriate direction of and communication with physical therapist assistants and support personnel. Further infonnation on supervision via applicable local, state, and federal laws and regulations (including state practice acts and administrative codes) is available. Infonnation on supervision via APT A policies and resources is also available on the APT A Web site. See Principles 5A and 5B. Integrity in Relationships Principle 4 states as follows: 4: Physical therapists shall demonstrate integrity in their relationships with patients/clients, families, colleagues, students, research participants, other health care providers, employers, payers, and the public. (Core Value: Integrity) Interpretation: Principle 4 addresses the need for integrity in relationships. This is not limited to relationships with patients/clients, but includes everyone physical therapists come into contact with professionally. For example, demonstrating integrity could encompass working collaboratively with the health care team and taking responsibility for one's role as a member ofthat team.

14 6 Reporting Principle 4C states as follows: 4C. Physical therapists shall discourage misconduct by healthcare professionals and report illegal or unethical acts to the relevant authority, when appropriate. Interpretation: When considering the application of "when appropriate" under Principle 4C, keep in mind that not all allegedly illegal or unethical acts should be reported immediately to an agency/authority. The determination of when to do so depends upon each situation's unique set of facts, applicable laws, regulations, and policies. Depending upon those facts, it might be appropriate to communicate with the individuals involved. Consider whether the action has been corrected, and in that case, not reporting may be the most appropriate action. Note, however, that when an agency/authority does examine a potential ethical issue, fact finding will be its first step. The determination of ethicality requires an understanding ofall ofthe relevant facts, but may still be subject to interpretation. The EJC Opinion titled: Topic: Preserving Confidences; Physical Therapist's Reporting Obligation With Respect to Unethical. Incompetent, or Illegal Acts provides further information on the complexities of reporting. Exploitation Principle 4E states as follows: 4E. Physical therapists shall not engage in any sexual relationship with any of their patient/clients, supervisees or students. Interpretation: The statement is fairly clear - sexual relationships with their patients/clients, supervisees or students are prohibited. This component of Principle 4 is consistent with Principle 4B, which states: Physical therapists shall not exploit persons over whom they have supervisory, evaluative or other authority (e.g. patients/clients, students, supervisees, research participants, or employees). Next, consider this excerpt from the EJC Opinion titled Topic: Sexual Relationships With Patients/Former Patients: A physical therapist stands in a relationship oftrust to each patient and has an ethical obligation to act in the patient's best interest and to avoid any exploitation or abuse of the patient. Thus, if a physical therapist has natural feelings of attraction toward a patient, he/she must sublimate those feelings in order to avoid sexual exploitation of the patient.

15 7 One's ethical decision making process should focus on whether the patient/client, supervisee or student is being exploited. In this context, questions have been asked about whether one can have a sexual relationship once the patient/client relationship ends. To this question, the EJC has opined as follows: The Committee does not believe it feasible to establish any bright-line rule for when, ifever, initiation ofa romantic/sexual relationship with a former patient would be ethically permissible. Colleague Impairment The Committee imagines that in some cases a romantic/sexual relationship would not offend... if initiated with a former patient soon after the termination of treatment, while in others such a relationship might never be appropriate. Principle 5D and 5E state as follows: 5D. Physical therapists shall encourage colleagues with physical, psychological, or substance-related impairments that may adversely impact their professional responsibilities to seek assistance or counsel. 5E. Physical therapists who have knowledge that a colleague is unable to perform their professional responsibilities with reasonable skill and safety shall report the information to the appropriate authority. Interpretation: The central tenet ofprinciples 5D and 5E is that inaction is not an option for a physical therapist when faced with the circumstances described. Principle 5D states that a physical therapist shall encourage colleagues to seek assistance or counsel while Principle 5E addresses reporting information to the appropriate authority. 5D and 5E both require a factual determination on your part. This may be challenging in the sense that you might not know or it might be difficult for you to determine whether someone in fact has a physical, psychological, or substance-related impairment. In addition, it might be difficult to determine whether such impairment may be adversely affecting his or her professional responsibilities. Moreover, once you do make these determinations, the obligation under 5D centers not on reporting, but on encouraging the colleague to seek assistance. However, the obligation under 5E does focus on reporting. But note that 5E discusses reporting when a

16 8 colleague is unable to perform, whereas 5D discusses encouraging colleagues to seek assistance when the impairment may adversely affect his or her professional responsibilities. So, 5D discusses something that may be affecting performance, whereas 5E addresses a situation in which someone is clearly unable to perform. The 2 situations are distinct. In addition, it is important to note that 5E does not mandate to whom you report; it gives you discretion to determine the appropriate authority. The EJC Opinion titled: Topic: Preserving Confidences; Physical Therapist's Reporting Obligation With Respect to Unethical, Incompetent, or Illegal Acts provides further information on the complexities of reporting. Professional Competence Principle 6A states as follows: 6A. Physical therapists shall achieve and maintain professional competence. Interpretation: 6A requires a physical therapist to maintain professional competence within one's scope of practice throughout one's career. Maintaining competence is an ongoing process of self-assessment, identification ofstrengths and weaknesses, acquisition of knowledge and skills based on that assessment, and reflection on and reassessment of performance, knowledge and skills. Numerous factors including practice setting, types ofpatients/clients, personal interests and the addition of new evidence to practice will influence the depth and breadth ofprofessional competence in a given area of practice. Additional resources on Continuing Competence are available on the APT A Web site. Professional Growth Principle 6D states as follows: 6D. Physical therapists shall cultivate practice environments that support professional development, life-long learning, and excellence. Interpretation: 6D elaborates on the physical therapist's obligations to foster an environment conducive to professional growth, even when not supported by the organization. The essential idea is that this is the physical therapist's responsibility, whether or not the employer provides support. Charges and Coding Principle 7E states as follows: 7E. Physical therapists shall be aware of charges and shall ensure that documentation and coding for physical therapy services accurately reflect the nature and extent of the services provided.

17 9 Interpretation: Principle 7E provides that the physical therapist must make sure that the process ofdocumentation and coding accurately captures the charges for services performed. In this context, where charges cannot be determined because ofpayment methodology, physical therapists may review the House of Delegates policy titled Professional Fees for Physical Therapy Services. Additional resources on documentation and coding include the House of Delegates policy titled Documentation Authority for Physical Therapy Services and the Documentation and Coding and Billing information on the APT A Web site. Pro Bono Services Principle SA states as follows: 8A. Physical therapists shall provide pro bono physical therapy services or support organizations that meet the health needs ofpeople who are economically disadvantaged, uninsured, and underinsured. Interpretation: The key word in Principle 8A is "or". If a physical therapist is unable to provide pro bono services he or she can fulfill ethical obligations by supporting organizations that meet the health needs of people who are economically disadvantaged, uninsured, and underinsured. In addition, physical therapists may review the House of Delegates guidelines titled Guidelines: Pro Bono Physical Therapy Services. Additional resources on pro bono physical therapy services are available on the APT A Web site. 8A also addresses supporting organizations to meet health needs. In terms of supporting organizations, the principle does not specify the type of support that is required. Physical therapists may express support through volunteerism, financial contributions, advocacy, education, or simply promoting their work in conversations with colleagues. Issued by the Ethics and Judicial Committee American Physical Therapy Association October 1981 Last Amended November 2010 Last Updated: Contact: ejc@apta,org

18 BAPTA American Physical Therapy Association The Science of Healing. The Art of Carin,;. GUIDELINES: PHYSICAL THERAPIST SCOPE OF PRACTICE BOD G [Retitled: Model Definition of Physical Therapy for State Practice Acts; Amended BOD ; BOD ; BOD ; BOD ; BOD ; BOD ; Initial BOD ] [Guideline] Physical therapy, which is limited to the care and services provided by or under the direction and supervision of a physical therapist, includes: 1) examining (history, system review and tests and measures) individuals with impairment, functional limitation, and disability or other health-related conditions in order to determine a diagnosis, prognosis, and intervention; tests and measures may include the following: aerobic capacity/endurance anthropometric characteristics arousal, attention, and cognition assistive and adaptive devices circulation (arterial, venous, lymphatic) cranial and peripheral nerve integrity environmental, home, and work Uob/school/play) barriers ergonomics and body mechanics gait, locomotion, and balance integumentary integrity joint integrity and mobility motor function (motor control and motor learning) muscle performance (including strength, power, and endurance) neuromotor development and sensory integration orthotic, protective, and supportive devices pain posture prosthetic requirements range of motion (including muscle length) reflex integrity self-care and home management (including activities of daily living and instrumental activities of daily living) sensory integrity ventilation, and respiration/gas exchange work Uob/school/play), community, leisure integration or reintegration (including instrumental activities of daily living) 2) alleviating impairment and functional limitation by designing, implementing, and modifying therapeutic interventions that include, but are not limited to: coordination, communication and documentation patient/client-related instruction therapeutic exercise functional training in self-care and home management (including activities of daily living and instrumental activities of daily living)

19 functional training in work Uob/school/play) and community and leisure integration or reintegration activities (including instrumental activities of daily living, work hardening, and work conditioning) manual therapy techniques (including mobilization/manipulation) prescription, application, and, as appropriate, fabrication of devices and equipment (assistive, adaptive, orthotic, protective, supportive, and prosthetic) airway clearance techniques integumentary repair and protection techniques electrotherapeutic modalities physical agents and mechanical modalities 3) preventing injury, impairment, functional limitation, and disability, including the promotion and maintenance of health, wellness, fitness, and quality of life in all age populations 4) engaging in consultation, education, and research Relation to Vision 2020: Evidence Based Practice (State Government Affairs, ext 8533) [Document updated: 12/14/2009] Explanation of Reference Numbers: BOD POO-OO-OO-OO stands for Board of Directors/month/year/page/vote in the Board of Directors Minutes; the "P" indicates that it is a position (see below). For example, BOD P means that this position can be found in the November 1997 Board of Directors minutes on Page 6 and that it was Vote 18. P: Position I S: Standard I G: Guideline I Y: Policy I R: Procedure

20 BAPTA American Physical Therapy Association The Science of Healin~. The Art of Carin!;. STANDARDS OF PRACTICE FOR PHYSICAL THERAPY HOD S [Amended HOD S ; HOD S ; HOD ; HOD ; HOD ; HOD ; HOD ; Initial HOD ; HOD ] [Standard] Preamble The physical therapy profession's commitment to society is to promote optimal health and functioning in individuals by pursuing excellence in practice. The American Physical Therapy Association attests to this commitment by adopting and promoting the following Standards of Practice for Physical Therapy. These Standards are the profession's statement of conditions and performances that are essential for provision of high quality professional service to society, and provide a foundation for assessment of physical therapist practice. I. Ethical/Legal Considerations A. Ethical Considerations The physical therapist practices according to the Code of Ethics of the American Physical Therapy Association. The physical therapist assistant complies with the Standards of Ethical Conduct for the Physical Therapist Assistant of the American Physical Therapy Association. B. Legal Considerations The physical therapist complies with all the legal requirements of jurisdictions regulating the practice of physical therapy. The physical therapist assistant complies with all the legal requirements of jurisdictions regulating the work of the assistant. II. Administration of the Physical Therapy Service A. Statement of Mission, Purposes, and Goals The physical therapy service has a statement of mission, purposes, and goals that reflects the needs and interests of the patients/clients served, the physical therapy personnel affiliated with the service, and the community. B. Organizational Plan The physical therapy service has a written organizational plan. C. Policies and Procedures The physical therapy service has written policies and procedures that reflect the operation, mission, purposes, and goals of the service, and are consistent with the Association's standards, policies, positions, guidelines, and Code of Ethics. D. Administration A physical therapist is responsible for the direction of the physical therapy service. E. Fiscal Management The director of the physical therapy service, in consultation with physical therapy staff and appropriate administrative personnel, participates in the planning for and allocation of resources. Fiscal planning and management of the service is based on sound accounting principles.

21 F. Improvement of Quality of Care and Performance The physical therapy service has a written plan for continuous improvement of quality of care and performance of services. G. Staffing The physical therapy personnel affiliated with the physical therapy service have demonstrated competence and are sufficient to achieve the mission, purposes, and goals of the service. H. Staff Development The physical therapy service has a written plan that provides for appropriate and ongoing staff development. I. Physical Setting The physical setting is designed to provide a safe and accessible environment that facilitates fulfillment of the mission, purposes, and goals of the physical therapy service. The equipment is safe and sufficient to achieve the purposes and goals of physical therapy. J. Collaboration The physical therapy service collaborates with all disciplines as appropriate. III. PatienUClient Management A. Physical Therapist of Record The physical therapist of record is the therapist who assumes responsibility for patienuclient management and is accountable for the coordination, continuation, and progression of the plan of care. B. PatienUClient Collaboration Within the patienuclient management process, the physical therapist and the patienuclient establish and maintain an ongoing collaborative process of decision making that exists throughout the provision of services. C. Initial Examination/Evaluation/Diagnosis/Prognosis The physical therapist performs an initial examination and evaluation to establish a diagnosis and prognosis prior to intervention. D. Plan of Care The physical therapist establishes a plan of care and manages the needs of the patienuclient based on the examination, evaluation, diagnosis, prognosis, goals, and outcomes of the planned interventions for identified impairments, activity limitations, and participation restrictions. The physical therapists involve the patienuclient and appropriate others in the planning, implementation, and assessment of the plan of care. The physical therapist, in consultation with appropriate disciplines, plans for discharge of the patienuclient taking into consideration achievement of anticipated goals and expected outcomes, and provides for appropriate follow-up or referral. E. Intervention The physical therapist provides or directs and supervises the physical therapy intervention consistent with the results of the examination, evaluation, diagnosis, prognosis, and plan of care. F. Reexamination The physical therapist reexamines the patienuclient as necessary during an episode of care to evaluate progress or change in patienuclient status and modifies the plan of care accordingly or discontinues physical therapy services.

22 G. Discharge/Discontinuation of Intervention The physical therapist discharges the patienuclient from physical therapy services when the anticipated goals or expected outcomes for the patienuclient have been achieved. The physical therapist discontinues intervention when the patienuclient is unable to continue to progress toward goals or when the physical therapist determines that the patienuclient will no longer benefit from physical therapy. H. Communication/Coordination/Docu mentation The physical therapist communicates, coordinates, and documents all aspects of patienuclient management including the results of the initial examination and evaluation, diagnosis, prognosis, plan of care, interventions, response to interventions, changes in patienuclient status relative to the interventions, reexamination, and discharge/discontinuation of intervention and other patienuclient management activities. The physical therapist of record is responsible for "hand off' communication. IV. Education The physical therapist is responsible for individual professional development The physical therapist assistant is responsible for individual career development The physical therapist and the physical therapist assistant, under the direction and supervision of the physical therapist, participate in the education of students. The physical therapist educates and provides consultation to consumers and the general public regarding the purposes and benefits of physical therapy, The physical therapist educates and provides consultation to consumers and the general public regarding the roles of the physical therapist and the physical therapist assistant. V, Research The physical therapist applies research findings to practice and encourages, participates in, and promotes activities that establish the outcomes of patienuclient management provided by the physical therapist. VI. Community Responsibility The physical therapist demonstrates community responsibility by participating in community and community agency activities, educating the public, formulating public policy, or providing pro bono physical therapy services. (See also Board of Directors standard Criteria for Standards of Practice) Relationship to Vision 2020: Professionalism; (Practice Department, ext 3176) [Document updated: 02/03/2011] Explanation of Reference Numbers: BOD POO-OO-OO-OO stands for Board of Directors/month/year/pagelvote in the Board of Directors Minutes; the "P" indicates that it is a position (see below). For example, BOD P means that this position can be found in the November 1997 Board of Directors minutes on Page 6 and that it was Vote 18, P: Position I S: Standard I G: Guideline I Y: Policy I R: Procedure

23 Summarv: Standards For Privacy Ofindividually Identifiable Health Information (Privacy Rule 45 CFR Part 160 And Subparts A And E Of Part 164) INTRODUCTION With the rapid advances in electronic technology, concerns have grown that the privacy of sensitive health care information will be jeopardized. Because no national standard exists to protect personal health infonnation, credible risks exist that it could be distributed without appropriate notice or authorization for uses that had nothing to do with a patient's medical treatment or reimbursement for health care services. Thus, in 1996 Congress passed the Health Information Portability and Accountability Act (HIPAA), mandating the adoption of Federal privacy protections for individually identifiable health infonnation. In response to this mandate, the Department of Health and Human Services (HHS) published the Privacy Rule in the Federal Register on December 28, Subsequently, on August 14, 2002, HBS issued a finalmle making modifications to the Privacy Rule. The final Privacy Rules are available at and specific guidance (including questions and answers) on the Privacy Rule from the HHS Office of Civil Rights is available at hup:llwww.hhs.gov/ocr!hipaa/privacy.html. The Privacy Rule provides, for the first time, comprehensive Federal protection for the privacy of health infonnation. The Privacy Rule sets a Federal floor of safeguards to protect the confidentiality of infonnation. The Rule does not replacc Federal, State, or other law that provides individuals even greater privacy protections. In developing the Privacy Rule, HHS worked to create a balance that would provide strong privacy protections, while not interfering with patient access to, or the quality of health care services. This summary provides an explanation of the requirements of the Privacy Rule. WHO IS COVERED? The Privacy Rule applies to three types of covered entities (ee): health plans, health care clearinghouses, and health care providers who conduct certain health care transactions (e.g. electronic billing, funds transfers, etc.) electronically. The Department of Health and Human Services Office of Civil Rights has a tool on their website at go v Ihipaa/hipaa2/support/too lsidec isionsupport! defaul t asp that providers and plans can use to detennine whether or not they would be considered a covered entity. Covered entities must comply with the Privacy Standards by Apri I 14, The Rule requires that the average health care plan or health care provider: 1) notify patients about their privacy rights and how their infomlation can be used; 2) adopt and implement privacy procedures; 3) train employees so that they understand the privacy

24 procedures; 4) designate an individual responsible for ensuring that privacy procedures are adopted and followed; and 5) secure patient records containing individually identifiable health infonnation. Many physical therapists have already taken these steps. STATE LAW PREEMPTION Privacy Standards create a minimal floor of protection. HIPAA privacy regulations would preempt contrary state laws unless the state law is more stringent and relates to privacy of health infonnation. States are now starting to put more stringent laws in place. Infonnation on state privacy laws is available at nocat2304/info-url nocat.htm INCIDENTAL USES AND DISCLOSURES The Privacy Rule generally requires covered entities to make reasonable efforts to limit the use or disclosure of, and requests for, protected hcalth infonnation to the minimum necessary to accomplish the intended purpose. In addition, the Privacy Rule requires covered entities to implement appropriate administrative, technical, and physical safeguards to reasonably safeguard protected health information from any intentional or unintentional use or disclosure that violates the Rule. Protected health information (PHI) includes individually identifiable health infonnation in any fonn, including infonnation transmitted orally, or in written or electronic fonn. This provision of the Privacy Rule raised many concerns among providers who feared that they could no longer engage II1 confidential conversations with other providers or patients, if there is a possibility that they could be overheard. The concerns stemmed from the perception that covered entities are required to prevent any incidental disclosure such as those that may occur when a visiting family member or other person not authorized to access PHI happens to walk by material containing individually identifiable health infonnation, or when a patient signs in on a log in sheet and sees other patients'names. HHS has clarified that the Privacy Rule is not intended to prevent customary and necessary health care communications or practices from occurring. Thus, they do not require that risk of incidental use or disclosure be eliminated to meet the standards. Rather, the Privacy Rule pennits incidental uses or disclosure that occur as a by-product of a use or disclosure otherwise pennitted under the rule. An incidental use or disclosure is pennissible if the covered entity has applied reasonable safeguards, and implemented the minimum necessary standard, where applicable. The covered entity must have in place appropriate administrative, technical, and physical safeguards that limit incidental uses and disclosures. The covered entity's safeguards do not have to guarantee the privacy of protected health infonnation from any and all potential risks. The Privacy Rule recognizes that oral communications often must occur 2

25 freely and quickly in treatment settings. Thus, safeguards will vary from covered entity to covered entity depending on factors, such as the size of the covered entity and the nature of its business. In determining what is reasonable, CEs should assess potential risks to patient privacy, potential efiects of patient care, and any administrative or financial burdens to be incurred. They should consider the steps other professionals are taking to protect privacy. Examples of reasonable safeguards would be: I) speaking quietly when discussing a patient's condition in the waiting room with the D:llnily; 2) avoid using patient's names in public hallways; 3) locking file cabinets or records rooms; and 4) Providing additional passwords on computers. HHS has specified that: Providers (such as physical therapists) would not have to retrofit their orfices, provide private rooms or soundproof walls to avoid a possibility that a conversation would be overheard. Where multiple patient-physical therapist communications routinely occur, use of cubicles, dividers, shields, or curtains may constitute reasonable safeguard, rather than separate rooms. Many physical therapy practices have gyms where several patients receive exercise therapy at the same time. ThIs situation is permissable as long as detailed discussions of treatment and prognosis are done in a more private setting, like behind a room divider. Providers can leave messages for patients on their answering machmes, although they should take care to limit the amount of information disclosed on the answering machine (e.g. they may want to leave only the name and other to confirm an appointment). They could also leave a message with the person that answers the phone, but should use professional judgment in limiting disclosures. Patient sign-in sheets or calling out patient names in waiting rooms is acceptable as long as the information disclosed is appropriately limited. For example, the sign in sheet should not include the reason for the visit. Mamtaining patient charts at bedside or outside of exam rooms is acceptable, but the provider should take safeguards to limit access to these areas. Safeguards could include ensuring the area is supervised, escorting non-employees in the area, or face the chart down or toward a wall. An incidental use or disclosure that occurs as a result of a failure to apply reasonahle safeguards or the minimum necessary standard, where required would be a violation of the Privacy Rule. For example, a hospital that permits an employee to have unimpeded access to patients' medical records, where this access is not necessary for the employee to perform her Job, is not applying the minimum necessary standard. Therefore, any incidental use or disclosure that results from this practice would be an unlawful disclosure under the privacy rule. Covered entities are not required to include incidental disclosures in an accounting of disclosures provided to the individual. 3

26 In addition, under the Privacy Rule it is generally permissable for a covered entity to disclose protected health infonnation to a family member or other person involved in the individual's care. Where the individual is present during a disclosure, the covered entity may disclose protected health infonnation if it is reasonable to infer from the circumstances that the individual does not object to the disclosure. MINIMUM NECESSARY STANDARD The Privacy Rule generally requires con:red entities to make reasonable efforts to limit the use or disclosure of, and requests for, protected health infonnation to the minimum necessary to accomplish the intended purpose. There are some exceptions to the minimum necessary rule. The requirements do not apply to: 1) uses or disclosures that are required by law; 2) disclosures to the individual who is the subject of the infonnation; 3) uses or disclosures for which the CE has received an authorization that meets the necessary requirements (the authorization identifies the minimum necessary)-the authorization must meet the appropriate requirements. 4) disclosures to or requests by a health care provider for treatment purposes (e.g. a physical therapist is 'not required to apply the minimum necessary standard when discussing a patient's plan of care with a physician); 5) uses or disclosures that are required for compliance with the regulations implementing the other administrative simplification provisions of HIPAA, or disclosures to HHS for purposes of enforcing the rule. A CE is required to develop and implement policies and procedures that reasonably minimize the amount of PHI, used, disclosed, and requested. These policies and procedures must identify the persons or classes of persons who need access to the infonnation to carry out their job duties, the categories or types of protected health infonnation needs, and the conditions appropriate to access. For routine or recurring requests and disclosures, the policies and procedures may be standard protocols. For example, policies and procedures with respect of disclosure to accrediting organizations could be set forth in advance. Non-routine requests must be reviewed individually, most likely by the privacy officer. For example, the provider would not be able to anticipate in advance that a law enforcement agency would request certain intonnation about the patient. In certain circumstances, the Rule pennits a CE to reasonably rely on the judgment of the party requesting the disclosure as to the minimum amount of infonnation that is needed. This reliance is pennitted for requests made by a public official or agency, another covered entity, a business associate, and a researcher. With respect to business associates, the CE is obligated to instruct its business associates to request only the minimum amount of infonnation necessary. 4

27 The minimum necessary standard permits a CE to disclose PHI to comply with workers' compensation or other similar programs established by law that provide benefits for work-related injuries or illnesses without regard to fimlt. Specifically, the mfonnatlon should be shared to the full extent permitted by state law. PERSONAL REPRESENTATIVES The Federal Government recognizes that there may be instances where indi\iduals are incapable of exercising their privacy rights or designate another individual to act on their behalf \\ith respect to these rights. According to the rule, a person authorized to all on behalf of the individual in making health care related decisions is the individual's "personal representative." For the most part, the Privacy Rule requires covered entities to treat an individual; personal representative as the individual with respect to uses and disclosures of the individual's protected information and with respect to the individual's rights under the Rule. Essentially, the personal representative "stands in the shoes" of the individual and thus can exercise the individual's rights. Thus, if the personal representative requests an accounting of disclosures, the physical therapist must provide him or her with this accountmg. The personal representative may also authorizc disclosures of the individual's PHI. State or other law should be examined to detennine the authority of the personal representative also. PARENTS AS PERSONAL REPRESENTATIVES OF UNEMANCIPATED MINOR The Fmal mle defers to the State or other applicable law regarding a parent' s access to health infonnation about a minor. Thus, State or other applicable law govems when the law explicitly requires, permits, or prohibits access to protected health infoll11ation about a minor to a parent. (This relates to disclosure of protected ll1[ormation to the parentdisclosure is about a covered entity providing mdividually identifiable health infonmltwn to persons outside the entity, either the individual or a third party.) The Privacy Rule specifies three circumstances in which the parent is not the "personal representative" with respect to certain information about the minor. In these situations the parent does not control the health care decisions and thus does not control the PHI. These occur: I) when state or other law does not require the consent of a parent or other person before a mmor can obtain a particular health care service, and the minor consents to the health care service (e.g. a state law provides the right to obtain mental health treatment without parental consent); 2) when a court determines someone other than the parent makes decisions; 3) when a parent agrees to a confidential relationship between the minor and physician. Even in these circumstances, the Privacy Rules defers to State or other laws that require, permit or prohibit the CE to disclose to a parent. In addition, in these situations, if State or other law is silent or unclear concerning parental access, a CE has discretion to provide or deny a parent with access to the health mformation, so long as the 5

28 decision is made by a licensed health care professional in the exercise of professional judgment. BUSINESS ASSOCIATES Most health care providers use the services of a variety of other persons or businesses to carry out their health care activities and functions. A business associate (BA) is defined as a "person or entity that perforn1s cel1ain functions or activities that involve the use or disclosure of protected health information on behalf of, or providers services to, a covered entity." A member of the covered cntity's workforce is not a business associate. Business associate functions and activities include: claims processing or administration; data analysis, processing or administration; utilization review; quality assurance; billing; and practice management. Business associate services are legal, actuarial, accounting, consulting, data aggregation, management, accreditation, and financial. Examples would include an attorney, a billing company, and an accountant. The Privacy Rule permits providers to disclose protected health information to these "business associates" if the providers obtain assurances the BA will use the information only for the purposes for which it was engaged by the CE, will safeguard the inforn1ation from misuse, and will help the CE to comply with its duties under the Privacy Rule. The Privacy Rule requires a covered entity to pmvide an accounting of certain disclosures, including disclosures by its business associate, to the individual upon request. The business associate's contract must provide that the business associate will make such information available to the covered entity so Ihat the covered entity can fulfill its obligation to the individual. The provider mllst obtain these assurances in writing either in the form of a contract or agreement. The Privacy Rule outlines certain provisions that must be included in the written contract or agreement. Sample business associate contract language is available at the HHS Privacy website at htlp:/!w\vw,hhs. goviocrlh!pna/contractprov.html Ifa CE knows of a privacy breach by the business associate, the CE must take reasonable steps to remedy the breach or end the violations. If these steps are unsuccessful, they must terminate the contract. If tennination is not a possibility, the CE must report the problem to DHHS Office of Civil Rights. Covered entities that ha\c an existing written contract with a business associate prior to October 15,2002 may contillue to operate under that contract for up to one additional year beyond April 14, 2003 so long as the contract is not revised or modified prior to April 14,2003. However, it is a good idea for providers (e.g. physical therapists) to obtain business associate contracts immediately, because the provider will have other obligations under the Privacy Rule. For example, the patient may request certain information that the business associate possesses. The provider is obligated to provide the patient with this information, but may not be able to get this information easily without a business associate agreement in place.

29 The provider IS not required to get a business associate agreement for disclosures by a covered entity to a health care provider for the treatment ofan individual. For example, if a physical therapist discloses treatment information to a physician about a patient that physician would not be considered a business associate. HHS recently clarified that when a financial institution processes consumer-conducted financial transactions by debit, eredit, or other payment card, clears checks, initiates or processes electronic funds transfers or eon ducts any other activity that effects the transfer of funds for payment for health care, it is providing its normal banking services. Therefore, it is not performing a function or activity for, or on behalf of the, covered entity. Also, a researcher is not considered a BA. DISCLOSURES F'OR TREATlVlENT, PAYMENT AND HEALTH CARE OPERATIONS The Privacy Rule pennits a covered entity to use and disclose protected health inf(jrmation without the patient's consent, for treatment, payment, and health care operations activities. Treatment generally means the provision, coordination, or management of health care and related among health care providers or by a health care provider with a third party, consultations between health care providers regarding a patient, or the referral of a patient from one health care provider to another. "Payment" encompasses the vanous activities of health care providers to obtain payment or be reimbursed for their services and of a health plan to obtain premiums, to fulfill their covered responsibilities, and to obtain or provide reimbursement for the provision of health care. Common payment activities include determining eligibility or co\'erage unclei' a plan, adjudicating claims, billing and collection activities and justification oj charges. Health care operations are certain administrative, financial, legal, and quality improvement activities necessary to run the covered entity's business. These activities include conducting quality assessment; reviewing the competence or qualifications of health care professionals; accreditation; certification; conducting or arranging for medical review, legal, and auditing services; business management and general administrative activities, For example, a physical therapist may use protected information to consult with other providers about a patient's treatment. The therapist could send a copy of an individual's medieal record to another specialist. In addition, the covered entity may disclose protected health infonnation to another covered entity or a health care provider for the payment activities of the entity that receives the information. For example, if DME supplier provides some type ofdme to a one of the physical therapisfs patients, the physical therapist could send PHI to the DME supplier in order for that DME supplier to bill Medicare tor the equipment. A must develop policies to limit the disclosures of PHI for payment and health care operations to the minimum necessary. However, the provider is not required to apply the 7

30 minimum necessary standard to disclosures to or requests by a health care provider for treatment purposes. Individuals have the right to request restrictions on how the CE uses and discloses the PHI about them for treatment, payment, and health care operations. However, a CE is not required to agree to an individual's request for a restriction. If the provider agrees to the individual's request, then the provider would be bound by those restlictions, and would be in violation ofhipaa ifhe or she does not comply. NOTICE OF PRIVACY PRACTICES FOR PHI The Privacy Rule states that an individual has a right to adequate notice of how a covered entity may use and disclose the individual's PJ-ll. The Privacy Notice also should infonn the individual of his or her rights and the CE's obligations with respect to the infonnation. The CE must make the notice available to any person who requests it, and must post it prominently and make it available on any website it maintains. The provider is required to give the notice to the individual on the date of first service delivery, meaning first direct treatment relationship. Direct treatment refers to face- toface exchange with the patient and involves delivering results to the patient. For example, a radiologist in a darkroom gets and reads those images. The radiologist then reports the results to the treating physician. There is no face- to- face contact between the radiologist and the patient in this instance. Therefore, the radiologist would not be required to give a notice of privacy to the patient. However, If the radiologist read the results of a mammography and then \vent outside and spoke to the patient about the results, then there would be a direct treatment relationship, and notice would be required. The provider must make a good faith eff0l1 to get the individual's written acknowledgment that the notice was received. The Rule does not require an individual's signature to be on the notice. Instead, a covered entity is pennitted to have the individual sign a separate sheet or list, or simply to initial a cover sheet of the notice, if he or she chooses. However, it is a good idea to have the signature on the Privacy Notice because there will be less likelihood of a dispute over the presence of the signature. If the individual refuses to sign such an acknnwlcdgment, the provider should document his or her efforts to get the signature and the reason that it was not signed. If there is a good faith effort on the part of the provider, failure to obtain an individual's acknowledgment is not a violation of the rule. I f the first service deli very is provided over the I nternet or in some other electronic fonn, the provider should send the electronic notice automatically and make a good faith effort to obtain a return receipt that the individual has received the electronic notice. If there is an emergency treatment situation, the notice should be provided as soon as it is reasonably practicable. 8

31 If the first treatment encounter with the patient is over the phone, the CE can satisfy the notice requirements by mailing the notice to the individual no later than the day of that service delivery. The provider may include a tear-off sheet or other document with the notice that requests that the acknowledgement be mailed back to the provider. If the initial contact with the patient IS just to schedule an appointment, the notice and acknowledgement requirements may be satisfied when the individual altives at the provider's facility for his or her appointment. Prmiders may form organized health care aitangements (OHCA) thal \\ uuld enable one notice to cover a number of affiliated providers. Covered entities that participate in an OHCA can satisfy the notice requirements through the use of a Joint notice as long as certain requirements are met. The hospital privacy notice could reference nut just the hospital's uses and disclosures, but also the uses and disclosures of individual staff. For example, a physical therapist or physician could enter into an organized health care arrangement with a hospital If the patient goes to the hospital and gets a notice of privacy, subsequently when the physician or physical therapist comes to the hospital to treat the patient, there would be no need to give additional notice. However, if the patient later leaves the hospital and goes to the office of the physician or physical therapist to receive services, that office should give the patient their notice. Under the Final Privacy Rule, the provider can give the notice once to the patient Hnd that is adequate. However, state law may require that the notice be given more frequently. If the provider does not include a reservhtion clause in the original Notice of Privacy Practices that states that the provider reserves the right to change privacy practices at some future date, the provider is obligated to give the new notice to everyone if a change is made. RIGHT OF ACCESS AND COPIES The individual has the right of access to his or her designated record set, meaning Hny piece of infomlation that reflects a decision the provider makes regarding the patient. Thus, the patient has the right to look at the chart and other records, even records the provider thinks the patient will never see. For example, the provider sends a letter to a collection agency because the patient would not pay the copayment. The letter to the collection agency has protected information (names, dates of service, amount he owes the provider) to be used to collect the copayment. If the patient requests a designated record set, the provider is obligated to get it to the patient in 30 days (if the informmion IS onsite) or 60 days (if the information is offsite~~-e.g. a business associate has it). The provider can charge a reasonable copying cost. The provider cannot charge a search fee to track it down, however Ifthe state law says that the provider cannot charge greater than a certain amount per page, then the provider has to follow the stricter state requirement. The federal law creates a minimum floor protection. RIGHT OF ACCOUNTING OF DISCLOSURES OF PHI <)

32 Under the Privacy Rule, individuals have the right to receive an accounting ofdisclosures of PHI made by thecovered entity if they request such an accounting. This can be a difficult right to honor. The CE is not required to account for disclosures that are made by the CE to carry out treatment, payment, or health care operations, or disclosures to individuals of PHI information about them. In addition, the CE does not have to account for disclosures made pursuant to an authorization. The accounting must include the following. 1) Disclosures of PHI that OCCUlTed during the 6 years prior to the date of the request for accounting; 2) The date of each disclosure; the name of the entity or person who received the PHI; a briefdescription of the PHI disclosed: and a brief statement of the purpose of the disclosure The provider may charge the person the reasonable cost of the accounting if the individual requests more than one accollntmg in the 12- month period. The provider may not terminate the patient for requesting many accountings because this is a federal right and thus, the provider cannot take retaliatory action. RIGHT TO REQUEST AMENDMENTS A covered entity that created the protected health information contained in a designated record set has an obligation to the mdivlciual to amend any erroneous or incomplete information. The individual does not have the right to amend information that is maintai.ned by other entities the individual has authorized to have his or her information. The CE that has made these amendmcnts at the request for the individual is obligated to make reasonable efforts to notify other persons, such as business associates, that have the information that was amended. An example of a situation in which a pallent might request an amendment would be a personal injury case. Perhaps a chart states that the injury is the fault of the patient, but that is not the case. The patient demands that the ch311 be changed to reflect to true cause of the injury. The provider must comply if the requested change is accurate. However, if the information in the record is accurate, then the provider has no legal obligation to change the record. The provider can also refuse to make the change if the provider is not the original source of the information. For example, a physical therapist, as a consultant is given the information by a primary care physician. The physical therapist reflects that information in the medical record. The patient requests that the physical therapist amend it. The physical therapist can inform the patient that he or she is 110t the source of the information, and that the patient would have to go back to the OIiginal source of the record to change the information. If the primary care physician makes the change, they would then be responsible for informing the physical therapist to change his or her records. 10

33 If a provider makes the amendment, the rule addresses how this amendment should be made. Removing the original material is not a good idea. The best way to handle the situation would be to put a single line though it, date it, and explain why the change is being made. RIGHT TO REQUEST ALTERNATIVE MEANS AND METHODS AND ADDITIONAL RESTRICTIONS A patient can ask the provider for more protections than the HIPAA Privacy Rule provides. The provider has the option of saying "yes" or "no." If the provider says yes, then the provider is bound by that statement and obligated to take those additional steps. If the provider agrees to the additional restrictions but does not abide, it will be a violation ofhipaa. For example, a patient might say to a physical therapist, "I don't want you to sencl information to my house. Could you send it to a P.O. Box number')" The patient has that right to make the request. I f the physical therapist agrees and then sends the ll1formation to the wrong place, the physical therapist would be in violation of HIPAA. AUTHORIZATlONS The Privacy Rule requires individual authorization for uses and disclosures of r:imteclecl health information t()r purposes that are not otherwise permitted or required under the Rule. Thus, in determining whether an authorization is necessary, a physical therapist needs to be aware of what is "permitted" or "required" uses or disclosures under the Rule. According to the Rule, '"required'" use or disclosure of PHI includes an individual seeking access to IllS or her own PHL It also includes the Department of Health and Human Scrvices demanding the information for compliance and enforcement pulvoses to assess compliance with HIPAA. Permitted disclosures are uses and disclosures required by laws other than HIPAA. It includes public health activities (e.g. vital statistics, communicable disease, product recalls, certain employer reporting ofosha related workplace surveillance). It also includes disclosures concerning victims of domestic violence or elder abuse. Public policy lises and disclosures are also considered permissible without an authorization. Examples would include: Use and disclosure of health oversight activities (e.g., state licensure, Dept. of Justice), and government benefit programs (Medicare audits) Judicial and administrative proceedings {e.g. a court order, warrant, court subpoena for relevant information}. Law enforcement activities. Emergency situations with serious threats to health or safety Specialized government hmctions The secret service might need infollllation on a suspect to protect the President.} 11

34 Workers' compensation (is exempted only to the extent required by state law) Most research activities require written authonzation. There is a waiver provision that allows certain information to be used where the institutional review board (IRB) waives the requirement of written authorization. The IRB can make this determination if the disclosure involves only minimal privacy risks and research with PHI is impractical if authorization is required. For example, a researcher is conducting research on 12,000 admissions to an institution. The researcher could track down the individuals from the study 20 years later, but some of the individuals may have moved, or be deceased. The researcher could spend years trying to get vvritten authorization to make the research possible. One option for the researcher would be to go to an IRB and explain that it is not practical to get the authorization and that the researcher is using safeguards that will protect the patient" s privacy. In contrast, if the researcher IS conducting a study that enrolls patients who come in on a monthly basis and receive treatment and monitoring with lab tests, it is not impractical to get their authorization because they are seen monthly. To ensure that authorizations are voluntary, the Rule prohibits covered entities from conditioning treatment, payment, or eligibility lor benefits or enrollment in a health plan on obtaining an authorization. The Rule also permits, with limited exceptions, individuals to revoke an authorization at any time. According to the Rule, the authorization must include certall1 core elements, which are: I) A description of the information to be used or disclosed that identifies the information in a specific and meaningful fashion. 2) The name or other specific identification of the person, or class of persons, authorized to make the requested use of disclosure. 3) The name or class of persons to whom the covered entity may make the requested use or disclosure. 4) A description of each purpose of the requested useo or disclosure. When an individual initiates the authorization, it is sufficient to say '"at the request of the individual" if that individual does not want to specify. 5) An expiration date or expiration event. 6) Signature of the individual and date. In addition to the core elements, the authorization must contain statements adequate to place the individual on notice of: I) The individual's right to revoke the authorization m writing 2) The ability or inability to condition treatment, payment, enrollment or eligibility for benefits on the authorization (consequences to individual of refusal to sign). The authorization must be in plain language and the mdividual must received a copy of the signed authorization. 12

35 MARKETING The Privacy Rule definition ofmarketing is "a communication about a product or service that encourages recipients of the communication to purchase or use the product or service." Included in the definition of marketing is an arrangement wherein a covered entity discloses protected health information to another entity in exchange for direct or indirect renumeration. These forms of communication, without exception, require prior patient authorization providing explicit permission to use the patienfs protected health information in this way. Equally important in understanding the HIPAA provisions that concern marketing is understanding what is 110t considered marketing. If the communication is made to describe a health-rel,:ited product or service that is provided by the covered entity itsell~ it is not considered marketing. For physical therapists, a health-related product could be a therapy band, cervical pillow, or like item sold to patients at the treatment facility. The marketing provisions delineate the activities that are considered treatment rather than marketing. Communications conceming treatment of a patient are permissabjc without an authorization because they arc not considered marketing. Therefore, communications mmie for the purposes of case management or care coordination, including recommendations for alternative treatments or therapies, do not require an authorization. For example, if a physical therapist shared patient information with a nursing homc employee in order to plan the bcst care for that patient, this would not be considered marketing and therefore would not require authorization. A communication made during a face-to-face patient encounter, even if it is marketing, does not require an authorization. Likewise, giving patients promotional gifts of nominal value, such as a pen or magnet, would not require authorization. Outside of thc limited examples listed above about what is not considered markcting, the Privacy Rule requires a patient's written authorization before the patient's protected health infonnation can be used for marketing purposes. An example is as follows. A physical therapist gives the patient some samples of a therapeutic gel at the conclusion of an appointment. This would not require patient authorization because the procluct is of nom1l1al value and given during a face-to-face encounter. However, if the physical therapist then wanted to sell that patient's name to the company so they could contact the patient to encourage them to buy their products in the future, prior patient authorization would then be required. RESEARCH The research provisions oflhe Final Privacy Rule are very complex and apply mainly to cl1l1ical research conducted by universities and government agencies, however a health care provider can be affected by these provisions if they provide health care services to individuals who are the subjects of such research. Health care providers who are covered entities under the HIPAA Privacy Rule may use or disclose protectcd health information from existing databases or repositories for research purposes either with individual

36 authorization from the patient or with a waiver of authorization from an Institutional I~ \ iew Board (IRB) or an alternative body such as a Privacy Board. The Privacy Rule permits Privacy Boards to approve the use of patient data when the research poses only a minimal privacy risk to the individuals involved. Under the Final Privacy Rule, when authorization for research is sought directly from the patient, the authorization can be part ofan authorization form that requests permission for other uses and disclosures (such as marketing) and no longer needs to be a separate fom1. Included in the Privacy Rule provisions on research is a new set of standards for a.! illllled data set" for research purposes if a covered entity discloses limited infol1nation. The Privacy Rule lists what must be removed from the information for it to qualify as a "limited data set" and requires covered entities to enter into a "data use agreement" with the researcher, which is similar to a "business associate agreement" discussed earlier, in that the provider requires that the researcher protect the patient information in their possession. Examples of identifiers thai may be part of a "limited data set" are admission and discharge dates, age and date of death (if applicable), but may not include directly identifiable patient information. 14

37 IAPTA Last updated: I ~... Practice Setting Physical Therapist in Private Practice Certified Rehabilitation Agency PT Student Part A N/A N/A Part B Xl Xl PTA Student Part A Part B N/A N/A Xl Xl Comprehensive Outpatient Rehabilitation Facility N/A Xl Skilled Nursing Facility yl Xl Xl Hospital y3 X Xl Home Health Agency NAR X Xl Ipatien Rehabilitation Facility I y4 N/A I yl N/A Contact: advocacy@apta.org Key Y Reimbursable X: Not Reimbursable N/A: Not Applicable NAR: T\ot Addressed In Regulation. Please defer to state Inw. yl: Reimbursable: The minutes of student services count on the Minimum Data Set. However, Medicare requires that the professional therapist (the PT) provides skilled services and direction 10 a student who is participating in the service under line-of-sight supervision. Federal Register (J lily 30, \999). In addition, effective October 1, CMS implemented additional rules regarding the student services based on PT/PTA supervision and whether minutes can be recorded as individual, concurrent, or group therapy minutes (RAJ Version 3.0 Manual, September 2010) Examples: II/ order to record the minlltes (IS individllal therapv whell (f therapv stlldent is im'o/fed in the treatmellt oja resident, only one resident can be treated by tlte therapy stlldent (lnd the supervising therapist or assistant (jor Medicare PClrt A and Part B). Under Medicare Part A, the supervising therapist or assistant cannot be treating or supervising other individllals and the therapist or assistant Imlst be able to il/1ll1ediate(v inter...ene or assist the stl/dent {IS needed vvhile the stlldent (llld residellt (Ire both within line ojsight slipen isioll. The therapist or assiswlit could be attending to paperwork while supervising the student and resident. Under A1edicare Part A, when a therapy student is involved ~vith the treatment, and one o/the following occurs, the minlltes may he coded as C()1/(:lIrrcnt therapy: The thempv stlldent is treating one residellt ol1d the slijiervising therapist or (lssislollt is

38 treating another resident and the therapy student and the resident the student is treating are in line ofsight ofthe supervising therapist or assistant; or The therapy stlldent is treating t}vo residents, both of'whom are in line o/sight 0/ the therapy stlldellt and tlie slipen'isillg theropist or (JSSiSf{/l1t, (llid the theropist is not treating {lily residents {lnd not slipeltisillg other indil!idlluls; or The therapy student is /lot treating any residents and the sllpenjising theropist or assistant is treating two re,\'idellfs at the some time, regardless ofpayer source, both ofwhom (Ire ill line 0/ sight. Under Medicare Part A, when a therapy stlldent is involved with group therapy treatment, and on(' ofthefl)lim1'illg occllrs. the minlltes may he coded (IS group therapy: The therapy student is providing the group treotment (lnd all the residents participating in the group and the therapy student are in line ofsight ofthe supervising therapist or assistant }vho is 110t treating {lily residents and is not supervising other individuals (students or residents); or The slipervising therapist/assistallt is pnwidillg the gj:<jlip treatment and the therapy student is 1I0t prol'idillg treatment to (IllY rcsident Documentation: APTA recommends that the physical therapist co-sign the note of the physical therapist student and state that the PT was providing I ine-of-sight supervision of the student and was involved in the patient's care. y2: Reimbursable: The mmutes of student services count on the Minimum Data Set However, Medicare requires th::lt the PT/PTA provide!ine-of-sight supervision of physical therapist assistant (PTA) student services as appropriate within their state scope 0 f practice, See Y 1 Documentation: APT A recommends that the physical therapist and assistant should co-sign the note of physical therapist assistant student and state that the PTfPT A was providing line of sight supervision of the student and was involved in the patient's care. Also, the documentation should reflect the requirements as indicated for individual therapy, concurrent therapy, and group therapy see yl. y3: This is not specifically addressed in the regulations, therefore, please defer to state law and standards of professional practice, Additionally, the Part A hospital diagnosis related group (DRG) payment system is similar to that of a skilled nursing facility (SNF) and Medicare has indicated very limited and restrictive requirements for student services in the SNF setting. Documentation: Please refer to documentation guidance provided under yl y4: This is not specifically addressed in the regulations, therefore, please defer to state law and standards of professional practice. Additionally, the inpatient rehabilitation facility payment system is similar to that ofa skilled nursing facility (SNF) and Medicare has indicated very limited and restrictive requirements for student services in the SNF setting. X I: B. Therapy Students I. General 2

39 Only the senjices o/the therapist can be billed and paid under lviedic(lre Part B. The sell'ices perj'ormed by a student are not reimbursed even ifprovided IInder "line olsight" SlllJf!ITision 0/the therapist: howe'ver, the presence ofthe student "in the room" does not nulke the scltice IIIIhilla ble, EXAMPLES: Therapists may bill and be paidjor the provision o/services in thefo!lml'illg SU'IlOlios, The q/lalijied practitioner is present and in the room for the ell tire' session, The stlldellt porticipulcs ill the delivefy o/services when the qualified practitioner is directillg tlie scn'ic(:', IIwkilzg thc skilled judgment, and is re~ponsiblefor the assessii1cllt {fnd trcu/lncli! The qllolijied practitioner is present in the room glliding the stlldcllt ill SClTicc dcliv('iy,v/wi1 the therapy stlldent and the therapy assistant stl/dcn! (Ire purficipollllg in flie provision ojservices, and the practitioner is not engaged in treating ol/otlier puticlit or c/oing other tasks {It the same time, The qllu/i/iee/ practitioner is re~ponsib!efor the services owl as SlIclt. siglls 01/ doclilllentalion, (A stltdenr may, a/course, also sign bllt it is llot l/cccssult sillce Ihe Part B fjuymel/t is/or the clinician's service, notfor the stlle/ellt '.\ s('nices) 2. Therapy Assistants as Clinical Instructors Physical fherapist (lssistants and occupational therapy assistaliis (Ire I/Ot /Jrec/lli/cd (rolll,\i!rving as clillicul il/.\'trllc/orsjijr rherapy students, while providing sen'ices H'itliill f'lcir SCOI,e O!ll:;rk owl /Jcl/imncd IInder the direction (Ind supervision 0/a licensed physical or ()CCII110IlIIIlUI therapist fo {/ MediUlrc hcllc/iciory Documentation: APTA recommends that the physical therapist or physical therapist assistant complete documentation, 3

40 Use of Students under Medicare Part B IAPlA American Physical Therapy Association Home> Payment> Medicare> Supervision> Use of Students under Medicare Part B Use of Students under Medicare Part B The purpose of this document is to provide clarification on the circumstances under which physical therapy students may participate in the provision of outpatient therapy services to Medicare patients, and whether or not such services are billable under Medicare Part B. Specifically, this document addresses student participation in the provision of services in the following settings: private practice physical therapy offices, rehabilitation agencies, comprehensive outpatient rehabilitation facilities (CORFs), skilled nursing facilities (SNFs) (Part B), outpatient hospital departments, and home health agencies (Part B). Background CMS issued a program memorandum, (AB-01-56) on the provision of outpatient therapy services by therapy students on April 11, In this program memorandum ( CMS provided answers to frequently asked questions regarding payment for the services of therapy students under Part B of the Medicare program. In response to inquiries from the American Speech Language Hearing Association (ASHA), CMS issued a followup letter dated November 9, 2001, to ASHA in which they further clarified the policy on payment of student services that they outlined in the Q and A program memorandum. On January 10, 2002 CMS also issued a similar letter to AOTA on the subject. The follow-up letters to ASHA and AOTA were not intended to signify a change in the policy issued in the program memorandum; they were merely intended to provide further cia rification. Specifically, in the program memorandum (AB-01-56), CMS stated, in part, that "services performed by a student are not reimbursed under Medicare Part B. Medicare pays for services of physicians and practitioners (e.g. licensed physical therapists) authorized by statute. Students do not meet the definition of practitioners listed in the statute." Regarding whether services provided by the student with the supervising therapist "in the room" can be reimbursed, CMS stated that "Only the services of the therapist can be billed to Medicare and be paid. However, the fact that the student is "in the room" would not make the service un billable. Medicare would pay for the services of the therapist." In response to another question, CMS stated that "the therapist can bill for the direct services he/she provides to patients under Medicare Part B. Services performed by the therapy student are not payable under Medicare Part B." In the letter to ASHA, CMS once again restated, in order to be paid, Medicare Part B services must be provided by practitioners who are acting within the scope of their state licensure. CMS further described circumstances, under which they consider the service as being essentially provided directly by the qualified practitioner, even though the student has some involvement. Such services would be billable. Specifically, CMS states: "The qualified practitioner is recognized by the Medicare Part B beneficiary as the responsible professional within any session when services are delivered." "The qualified practitioner is present and in the room for the entire session. The student participates in the delivery of services when the qualified practitioner is directing the service, making the skilled juqgment, and is responsible for the assessment and treatment." "The qualified practitioner is present in the room guiding the student in service delivery when the student is participating in the provision of services, and the practitioner is not engaged in treating another patient or doing other tasks at the same time." h/l,/i011

41 Use of Students under Medicare Part B "The qualified practitioner is responsible for the services and as such, signs all documentation (A student may, of course, also sign but it is not necessary since the Part B payment is for the clinician's services, not for the student's services)." In response to a request from AOTA, CMS issued a summary of their understanding of the typical scenario involving students for which occupational therapists seek payment. The information provided in this letter mirrors what was stated in the letter provided to ASHA. Acceptable Billing Practices Based on the information provided by CMS and MedPAC, it is possible for a physical therapist to bill for services only when the services are furnished jointly by the physical therapist and student. APTA recommends that physical therapists consider the following factors in determining whether or not a physical therapist may bill Medicare Part B for a service when the therapy student is participating in the provision of the service. Physical therapists should use their professional judgment on whether or not a service is billable, keeping in mind the importance of integrity when billing for services. Physical therapists should distinguish between the ability of a student to provide services to a patient/client from the ability to bill for student services provided to Medicare Part B patients. A student may provide services to any patient/client provided it is allowable by state law. This does not mean, however, that the services provided by the student are billable to Medicare, Medicaid, or other private insurance companies. As CMS states, only services provided by the licensed physical therapist can be billed to Medicare for payment. Physical therapists should consider whether the service is being essentially provided directly by the physical therapist, even though the student has some involvement in providing the care. In making this determination, the therapist should consider how closely involved he or she is involved in providing the patient's care when a student is participating. The therapist should be completely and actively engaged in providing the care of the patient. As CMS states in their letter, "the qualified practitioner is present in the room guiding the student in service delivery when the student is participating the provision of services, and the practitioner is not engaged in treating another patient or doing other tasks at the same time." The therapist should direct the service, make the skilled judgment, and be responsible for the assessment and treatment. There should be checks and balances provided by the physical therapist throughout the entire time the patient/client is being managed. The physical therapist should ask him-or herself whether the billing would be the same whether or not there is a student involved. The therapist should not bill beyond what they would normally bill in the course of managing that patient's care. The individual therapist or the employer should not benefit financially from having the student involved in the clinical experience in the practice or facility. Conclusion It is crucial that physical therapists be aware of and comply with Medicare regulations governing the circumstances in which physical therapy students may participate in the provision of physical therapy services. CMS has clearly stated its policy that student services under Part B are not billable, and that only services provided to Medicare beneficiaries by the PT may be billed. APTA will continue to work to ensure that physical therapy students receiving the clinical training they need in order to provide valuable, high-quality physical therapy services to patients/clients. Last Updated: 4/7/2011 Contact: advocacy@apta.org '0' = Members Only h!,)'j!')()ll

42 TYPE OF PTA Aides/Technician FACILITY Acute care General supervision- in the building Require Direct line of sight supervision by hospitals (Part Physical therapy services must be a licensed therapist and is considered A) performed safely and/or effectively only by individual therapy for counting minutes. or under the general supervision of a skilled therapist. General supervision has been traditional described in HCFA manuals as requiring the initial direction and periodic inspection of the actual activity. However, the supervisor need not always be physically present or on the premises when the assistant is performing services When the therapist starts the session and delegates the performance of the therapy treatment to a therapy aide, while maintaining direct line of sight supervision, the total number of minutes of the therapy session may be coded as therapy minutes. Aides cannot independently provide a skilled service. Students Students may treat patients without therapist direct supervision Physical therapy services must be those services that can be safely and effectively performed only by or under the supervision of a qualified physical therapist. According to 42 CFR Section of the Medicare hospital conditions of participation, "physical therapy, if provided, must be provided by staff who meet the qualifications specified by medical staff, consistent with state law." Because the regulations do not specifically delineate the type of direction required, the provider must defer to his or her physical theraey Inpatient General supervision- in the building. Require Direct line of sight supervision by hospital therapy Physical therapy services must be those a licensed therapist and is considered (Part A) services that can be safely and effectively individual therapy for counting minutes. performed only by or under the supervision When the therapist starts the session and of a qualified physical therapist. Because delegates the performance of the therapy the regulations do not specifically delineate treatment to a therapy aide, while Students may treat patients without therapist direct supervision

43 Inpatient rehab facility (IRF) the type of di rection required, the provider maintaining direct line of sight must defer to his or her physical therapy supervision, the total number of minutes state practice act. of the therapy session may be coded as therapy minutes. Aides cannot independently provide a skilled service. General SUPE rvision- in the building. Technicians are not licensed and Physical then py services must be those unavailable to provide billable services services that an be safely and effectively therapy aides are expected to provide performed or Iy by or under the supervision support services to the therapists and of a qualified physical therapist. Because cannot be used to provide skilled therapy the regulatiol s do not specifically delineate services the type of di rection required, the provider must defer tc his or her physical therapy state practice act. Certified Rehab Agency eras are reql ired to have qualified personnel pn vide initial direction and periodic ObSE rvation of the actual performance of the function and/or activity. If the person providing services does not mee t the assistant-level practitioner c ualifications in , then the physical t herapist must be on the premises. In order for services to be reimbursed under Medicare Part B benefit, they may not be provided by a physical therapy aide regardless of level of supervision. ems's policy is that the therapy aide may assist the professional therapist or therapist assistant to perform a specific therapy service. The aide should never be the provider of the service. Skilled Nursing facility (SNF) Part B General supe rvision ( must be available by telephone or pager Technicians are not licensed and unavailable to provide billable services(as of ) therapy aides are expected to provide support services to the therapists and cannot be used to provide skilled therapy services neral Supervision@ is further manual as requiring the I Per the RAt manual instructions released Skilled rehabi itation services must be provided dire ctly or under the general supervision 0 skilled rehabilitation personnel. GE defined in the PT and student treat pt together. Pt in room guiding treatment. No other patients being treated during this time. **

44 initial d irection and periodic inspection of the act lal activity. However, the supervisor need n )t always be physically present or on the pre llises when the assistant is perfor ling services. GROUP supervision: 1 licensed provider/ per4 p'atients CORF,ORF Genera { teleph / ~ IIn-n HOSPITAL OP DEPT tgtrlpdfl42cfr pdf g JLmanualsLDownlo adslbp102c15.pdf: p 187 The se 'ices must be furnished by qualified person el. If the personnel do not meet the qualific Itions in , then the qualified staff m st be on the premises and must instruc these personnel in appropriate patien :are service, techniques, and retain respon ibility for their activities. A qualified profes Dnal representing each service made a railable at the facility must be either n the premises of the facility or must b available through direct telecom munications for consultation and assista ce during the facility=s operating hours Direct ne of site supervision by PT (must have P. supervision- cannot work without PT) Physica I therapy services must be those service ; that can be safely and ~ffellively on November 9, 2009, aides cannot be used to deliver skilled services. Aides should be used to provide support services and those services cannot be counted towards the minutes on the MDS. This policy is further detailed in the 2010 SNF PPS Final Rule. In order for services to be reimbursed under Medicare Part Bbenefit, they may not be provided by a physical therapy aide, regardless of level of supervision. ems's policy is that the therapy aide may assist the professional therapist or therapist assistant to perform a specific therapy service. The aide should never be the provider of the service Technicians are not licensed and unavailable to provide billable services In order for services to be reimbursed under Medicare Part B benefit, they may not be provided by a physical therapy aide PT and student treat pt together. Pt in room guiding treatment. No other patients being treated during this time. ** PT and student treat pt together. Pt in room guiding treatment. No other patients being treated during this time. ** i

45 ~ performed only by or under the supervision of a qualified physical therapist. Because the regulations do not specifically delineate the type of direction required, the provider must defer to his or her physical therapy state practice act. regardless of level of supervision. ems's policy is that the therapy aide may assist the professional therapist or therapist assistant to perform a specific therapy service. The aide should never be the provider of the service., I Outpatient Direct line of site supervision by PT (must Technicians are not licensed and PT and student treat pt Physical have PT in sight supervision- cannot work unavailable to provide billable services together. Pt in room guiding Therapy (Part B) without PT) treatment. No other patients Physical therapy services must be provided In order for services to be reimbursed being treated during this time. by or under the direct supervision of the under Medicare Part B benefit, they may ** physical therapist in private practice. ems not be provided by a physical therapy has generally defined direct supervision to aide, regardless of level of supervision. mean that the supervising private practice thera pist must be present in the office ems's policy is that the therapy aide may suite at the time the service is performed. assist the professional therapist or therapist assistant to perform a specific therapy service. The aide should never be the provider of the service, however, and employees must be personally supervised the physical therapist. POPTS (Part B) Direct line of site supervision by PT (must Technicians are not licensed and "PT and student treat pt have PT supervision- cannot work without unavailable to provide billable services together. Pt in room guiding PT) Effective July 25, 2005, in order for treatment. No other patients services to be reimbursed under Medicare being treated during this time. Services must be provided under the direct Part B benefit, they may not be provided ** supervision of a physical therapist who is by a physical therapy aide, regardless of enrolled as a provider under Medicare. A level of supervision physician cannot bill for the services provided by a PTA. The services must be billed under the provider number of the supervising physical therapist. ems has

46 Home Health Agency generally defined direct supervision to mean that the physical therapist must be in the office suite when an individual procedure is performed by supportive personnel. General supervision- by phone, does not Technicians are not licensed and PT and student treat pt have to be in the building. PTAs cannot perform home evaluations or home assessments Physical therapy services must be performed safely and/or effectively only by or under the general supervision of a skilled therapist. General supervision has been traditional described in HCFA manuals as requiring the initial direction and periodic inspection of the actual activity. However, the supervisor need not always be physically present or on the premises when the assistant is performing services. unavailable to provide billable services. together. Pt in room guiding treatment. No other patients being treated during this time. ** Under Medicare Part A regulations, all therapy services offered by the HHA, either directly or under arrangements, must be provided by a qualified therapist or a qualified therapist assistant under the therapist's supervision and in accordance with the plan of care. The qualified therapist assists the physician in evaluating level of function, helps develop the plan of care (revising as necessary), prepares clinical and progress notes, advises and consults with the family and other agency

47 personnel, and participates in in-service programs. (42 CFR ) Updated ** Students: Part B Therapy services: "The qualified practitioner is present and in the room for the entire session. The student participates in the delivery of services when the qualified practitioner is directing the service, making the skilled judgment, and is responsible for the assessment and treatment." "The qualified practitioner is present in the room guiding the student in service delivery when the student is participating in the provision of services, and the practitioner is not engaged in treating another patient or doing other tasks at the same time." "The qualified practitioner is responsible for the services and as such, signs all documentation (A student may, of course, also sign but it is not necessary since the Part B payment is for the clinician's services, not for the student's services)."

48 INTRODUCTION EXPERIENTIAL PROFESSIONAL ACTIVITIES (EPA) POLICIES AND PROCEDURES Supervised Experiential Professional Activities (EPAs) are an integral component of the professional educational program to help apply theories and procedures learned in the classroom setting to the professional practice of physical therapy. Full-time EPAs begin with a three-week block during summer I and subsequent EPAs continue throughout the program. The Department of Physical Therapy maintains contracts with a wide variety of professional settings to provide these experiences for the student. The purpose of the EPA is to provide the opportunity for the development of sufficient skill for safe and effective entry into the practice of physical therapy. Initially, a clinical instructor will closely supervise the EPA. Increasing responsibility will be given with each affiliation so that by the end of the professional education, the student should be functioning with minimal supervision. The information, which follows, explains the clinical curriculum, the responsibilities of those involved, and the policies and procedures. Completion of the requirements for the EPA phase of the professional curriculum is the student s responsibility. The HSU PT faculty monitors EPA policies and procedures. TITLES USED Director of Clinical Education (DCE) The academic program faculty member who is responsible for the EPA portion of the professional program. (This person is also known as the Academic Coordinator of Clinical Education (ACCE) at some professional physical therapy education programs.) Center Coordinator of Clinical Education (CCCE) The person at the contracted facility who is in charge of physical therapy education programs for the facility. This person may or may not be a clinical instructor. Clinical Instructor (CI) The physical therapist that directly supervises and evaluates the student during the EPA. EPA Students may only complete EPAs at assigned facilities which have a contract with HSU for providing EPA experiences for the students. A listing of the current facilities is available from the Director of Clinical Education. The Director of Clinical Education selects clinics based on the variety of experiences that they provide, staff expertise, and other factors. Suggestions from the students for future site development are encouraged and may be addressed to the Director of Clinical Education. It is the responsibility of the Director of Clinical Education, and not the student, to make contact with potential EPA sites. Clinical Site Information Forms (CSIF) are maintained in binders in the departmental work room for student reference. Each file includes experiences available, hours, locations, to whom to report, staffing, financial assistance, housing information, dress code, directions, etc. Feedback from students who have previously affiliated with the facility is also included. EPA Policies1

49 EVALUATION OF STUDENT EPA PERFORMANCE Each student will be evaluated using the PT MACS: Physical Therapist Manual for the Assessment of Clinical Skills. Students are each required to purchase and maintain their copy of the PT MACS and will be required to have documented entry level mastery (as recorded in the PT MACS by the clinical instructors [CIs]) of all skills specified in order to complete clinical affiliations. The PT MACS provides specific goals to work toward during the EPAs and documents progress toward competent practice. Formal training in the use of the PT MACS will be provided, but students should read the instructions in the PT MACS periodically for review. Remember, these are the MINIMUM PERFORMANCES REQUIRED; it is expected that the student will attain entry-level skills while on his/her clinical rotations. PHYSICAL THERAPIST STUDENT EVALUATION: CLINICAL EXPERIENCE AND CLINICAL INSTRUCTION Clinical facilities and CIs will need feedback on their performance in providing information, supervision and learning experiences. The APTA Physical Therapist Student Evaluation: Clinical Experience and Clinical Instruction is the form used for this purpose. In addition, each clinical site may have its own form. The Physical Therapist Student Evaluation: Clinical Experience and Clinical Instruction must be completed by the student prior to leaving the EPA, shared with the CI, signed by both the student and CI, and returned to the Director of Clinical Education. These forms are not meant to be threatening, but to facilitate open, honest, and constructive evaluation of the EPA experience. Students need to be honest in evaluating so that others may benefit from their experience. EPA EXPECTATIONS: Specific criteria are as follows: 1. In the 1 st Edition of the PT MACS, skills 1-11 are essential for professional practice and, therefore, required to be checked off ( ) as entry level on 3 of the 5 off-site clinicals. 2. #1 Commitment to Learning #2 Interpersonal Skills #3 Communication Skills: Oral and Written #4 Effective Use of Time and Resources #5 Use of Constructive Feedback #6 Problem Solving #7 Professionalism #8 Responsibility #9 Critical Thinking #10 Stress Management #11 Safety During Patient Management 3. If a specific PT MACS skill (#1-#19) is not completed at the end of EPA VI, the faculty will determine the action to be taken on a case-by-case basis. 4. The faculty retains the right to review the status of the PT MACS skill(s) completion for the purpose of additional EPA assignment if necessary. EPA Policies2

50 GRADING POLICIES The Program in Physical Therapy reserves the right to assign the grade to students. Refer to each EPA course syllabus for specific criteria for earning a passing grade. Possible grades for Clinical Education courses are: A, B, C as noted on the syllabus criteria. F Fail Any one of these examples may result in a grade of F: a. Significant number of the grading criteria were not met even though the necessary experiences were available or, b. Student demonstrated continuing deficiencies in areas of professional behavior or issues involving safety. I Incomplete These are examples which may result in a grade of I: a. Student completed a successful internship but learning experiences or patient populations were not adequate to complete the grading criteria or, b. Student had to withdraw due to illness or personal emergency or, c. Student was withdrawn at the discretion of the Director of Clinical Education and the Department Head. d. The number of NI s exceeds those allowed to meet A/B/C grade criteria. WP Withdraw Passing Used at the discretion of the DCE with faculty consultation for voluntary withdrawal from the program or in the event of significant absence from seminars or time lost during the internship due to illness or personal emergency. 1. Students must receive a passing grade of A, B, or C in clinical coursework. If a failing grade is earned, the student will be terminated from the program. 2. If a student earns a grade of I (Incomplete), the provisions for the removal of the Incomplete will be given to the student in writing. Grades of Incomplete in clinical internship courses will require additional clinical time to remove the Incomplete generally after the completion of all other clinical rotations. 3. If a student earns a grade of WP (Withdraw Passing), requirements to re-enroll in the course will be determined by the DCE. The student will be out-of-sequence and future internship scheduling will be determined by the DCE. EPA REMEDIATION/ DISCONTINUANCE A student, who in the eyes of the Clinical Instructor, is not progressing to the extent that he/she may not meet the minimal requirements for that affiliation, may need to develop a remediation plan as outlined below. Procedures for EPA Remediation: 1. The student must be notified of the potential for remediation from the clinical facility when he/she is failing to meet criteria. This should occur by midterm of the affiliation. 2. The student, in agreement with the CI, must complete a written plan with time frames for remaining at the clinical site and successfully completing certain skills. (See attached Remediation form.) EPA Policies3

51 3. If the terms of the plan are not met in the specified time, the internship will be terminated and the student will receive a grade of I (Incomplete), F (fail), or WP (Withdraw Passing) as determined to be appropriate by the DCE with faculty consensus. 4. Copies of the notification will be provided for the student, the clinical facility and the Department of Physical Therapy at HSU. Dismissal From a Clinical Site: A student may be removed from the clinical setting for the following reasons: 1. If after discussion between the Director of Clinical Education, CCCE and the CI it is determined that the student will not be able to successfully complete the EPA at that facility. 2. The student, in consultation with the Director of Clinical Education, determines that it is in the student s best interest to discontinue the EPA. 3. Personnel at the clinical site determine that the student poses an immediate threat or danger to personnel or to the quality of medical services. Also, the student may be removed for unprofessional behavior or if performance is unsatisfactory. Procedures for Dismissal from a Clinical Site: 1. Notification of dismissal can be extended at any time if the student exhibits unprofessional behaviors or is an immediate threat of danger to patients, other personnel or acts in a manner that threatens the quality of medical services. The notice must be made both verbally and in writing on the Notification of Dismissal from a Clinical Site form (attached). 2. Copies of the notification will be provided for the student, the clinical facility, and the Department of Physical Therapy at HSU. 3. A consensus of the HSU PT Departmental faculty will be required for decisions regarding whether the student will be allowed to continue in the Physical Therapy program or placed in an additional clinical site. APPEALS OF CLINICAL EDUCATION GRADES AND POLICIES Appeals can be made following the same guidelines as those for other courses and policies as listed in the Graduate Bulletin under Grade Appeal Process. COST OF EPAs Students should be prepared to incur additional expenses beyond tuition for EPAs including mandatory background checks and drug screens as required by many clinical sites. Since EPA assignments may be out-of-town or even out-of-state, students may need to maintain living arrangements here as well as pay for accommodations during the EPA. It will be the responsibility of the student to provide their own travel expenses to/from EPAs and to secure out-of-town housing. Clinical facilities may provide or be able to assist in obtaining housing. The personal situation of the student will be taken into consideration when making clinical assignments. HEALTH REQUIREMENTS FOR EPAs EPA Policies4

52 It is the student s responsibility to keep immunizations current and to comply with any other health requirements/documentation specified by the clinical facility to which they are assigned. Students must have health insurance while on EPAs. The student will provide a copy of these records for the departmental file. STUDENT PROFESSIONAL LIABILITY INSURANCE All students are required to have malpractice/professional liability insurance coverage. Purchase of this insurance under a group policy is handled by HSU and is a part of the registration fee each year. REQUIRED APPEARANCE FOR EPAs Unless otherwise notified, the following personal behavior and attire is mandatory during any patient contact: 1. Students will wear professional clothing: men will normally wear dress slacks, dress shirt or golf shirt with collar; women will wear dress slacks/skirt and blouse or shirt that can be tucked in and avoids exposure of breasts, midriffs, or buttocks. A lab coat and/or scrubs may be required at certain facilities. 2. Sensible shoes with closed toes and non-slip soles are appropriate. Athletic shoes, which are multi-colored, sandals, flip-flops, and high heels are not considered appropriate for the clinic. 3. HSU name badge (unless facility requires a hospital name badge). 4. Nails must be trimmed and long hair secured off face for safety in treating patients. 5. No large or excessive jewelry. 6. Earrings may only be worn in the earlobe; no multiple earrings. 7. Avoid excessive colognes, perfumes, and aftershaves. 8. Good personal hygiene. 9. No tattoos visible when treating patients. Students assigned to a clinical facility that requires a different personal and/or dress code, must follow that facility s requirements as noted in the EPA Information File. ABSENCE AND TARDINESS Tardiness or absence during an EPA or over a series of EPAs may result in an I (Incomplete) grade and a requirement for additional EPA assignment(s). Attendance at all scheduled EPAs is MANDATORY. An unexcused absence is reason for disciplinary action with possible termination from the program. In case of emergency or illness, an excused absence can be granted according to the following procedures. The student must: 1. Notify the CI or CCCE (according to facility policy) PRIOR to scheduled daily arrival time giving the reason necessitating the absence. The CI/CCCE will determine if the reason is appropriate for an excused absence; 2. If absences exceed one day per long term EPA, the missed time must be made up during that EPA at the discretion of the CI/CCCE; EPA Policies5

53 3. The makeup time will be determined by the CI/CCCE (according to facility policy) at a time deemed convenient for the clinic. Tardiness is to be avoided. Students must notify the CI or CCCE (according to the facility s policy) prior to the normal scheduled arrival time. EPA SITUATIONS REQUIRING DIRECTOR OF CLINICAL EDUCATION NOTIFICATION Most situations involving EPAs (e.g. sick, tardy, extra clinical days, daily concerns) can be handled between CI and student. However, the student MUST notify the Director of Clinical Education IMMEDIATELY if any of the following occur: 1. An extended absence is required due to sickness, injury, personal reasons, etc. 2. A significant on-the-job injury occurs that requires medical care. 3. An incident occurs that has potential malpractice/liability implications. 4. Problems arise with the EPA assignment that cannot be worked out with the clinical instructor. REPORTING TO EPA ASSIGNMENT Students are responsible for checking the EPA Information File for procedures regarding to whom and when to report before leaving for any EPA assignment. Students are required to write the clinical facility four to six weeks prior to the beginning of the affiliation to confirm the assignment and other arrangements. The student is then required to follow up with a phone call to the facility one week prior to beginning the EPA. Documentation of these requirements is to be provided to the Director of Clinical Education. Failure to meet the requirements may result in the cancellation of the EPA. MONITORING STUDENT PROGRESS DURING EPA The Director of Clinical Education calls or visits each student during each full-time EPA to discuss progress with the student and the CI. Mid-term evaluations will be made using the Progress Report in the PT MACS or a form provided by the Director of Clinical Education. PROCEDURES FOR ASSIGNMENT TO EPA SITES Availability of Sites: EPA sites are surveyed annually to determine the number of available student positions. Due to the variety of EPAs needed; it cannot be guaranteed that the student will have an EPA in a local facility. Students should plan on doing at least one EPA out of town. All effort will be made to take into account the personal situation of each student. It is in the student s best interest to experience numerous approaches to treatment, varied clinical settings, culturally diverse patient populations, and different means of documentation. EPA Policies6

54 Preliminary Activities: Through periodic counseling with the student and review of the PT MACS, the Director of Clinical Education will assist the student in identifying clinics available to meet the needed skill exposure. The Department cannot guarantee that students will be placed in the setting of their choice. ASSIGNMENT OF EPA SITES The Director of Clinical Education makes EPA assignments with the primary goal of providing each student with sufficient opportunity to attain mastery of entry-level skills in a variety of clinical settings. Occasionally, an EPA site will cancel the EPA on very short notice due to unforeseen circumstances. In such circumstances, the Director of Clinical Education will assist the student in identifying a suitable and timely alternative placement. Thus, the department cannot assume liability for delays in completion of the program or other losses/inconveniences sustained by the student under these circumstances. The Department will make reasonable and concerted efforts to find alternative placements when extenuating circumstances have precluded the student s participation in the experience. The Department believes it is not in the student s best interest to be placed in an EPA in which they plan to be employed following graduation. Thus students who are under contract or who anticipate working at a specific facility following graduation will not be assigned an EPA at that facility. RESPONSIBILITIES FOR THOSE INVOLVED IN EPAs The following are responsibilities, which are in addition to those stated elsewhere: The Facility must: 1. Provide learning experiences as available and appropriate for the student at that time; based on objectives of the Department, facility and student. 2. Provide supervision and counseling of student and document student s status using forms provided. 3. Coordinate, communicate, and report student s status to the Department by way of the designated facility Clinical Coordinator or Clinical Instructor. The Student must: Before Internships: 1. Have an overall grade point average of 3.0 based on a 4.0 grading scale at the end of the second fall semester of the curriculum. 2. Attend all clinical education seminars prior to participation in the scheduled clinical internship. Seminars and internships may occur in subsequent semesters. The actual course grade will include seminar participation and attendance as well as the internship requirements. 3. Have personal health insurance coverage before registering for any clinical education course and must furnish proof of this insurance. The University, as a part of the course fees, provides student liability insurance. The coverage is not valid unless a student is officially enrolled in the University. Student liability coverage is tied to actual course work and does not cover any students during part time or full time employment activities. EPA Policies7

55 4. Maintain responsibility for transportation, living arrangements, living expenses and telephone expenses related to clinical internships. 5. Meet the immunization requirements of the school and the facility. The Director of Clinical Education (DCE) will inform students of general health requirements and other requirements specific to a facility. The facility has the right to bar a student from clinical activities if proof of meeting all health requirements cannot be provided. Health forms, pictures and biographical data forms, current CPR certification must be submitted by the completion of the 2nd semester. 6. Have valid CPR certification during all clinical internships. Students will not be given time off from internships to revalidate the certificate. 7. Read the facility folder for the sites to which they have been assigned and respond to any specific request made by the facility that has been approved by the program. 8. Submit a written request to the DCE, along with appropriate documentation of inability to begin a scheduled internship, as soon as possible but prior to the starting date to request postponement of the internship. 9. Meet all requirements of the assigned clinical facility. Drug screens and/or a criminal background check may be required by clinical facilities. If the student is unable to be cleared on these requirements, the student may not be eligible to continue in the program. Expense for such testing/screening will be the student s responsibility. 10. Direct any request regarding scheduling of internships, exceptions for personal reasons or other requests that may affect the Clinical Education Policies to the DCE. The DCE may ask that the student put the request in writing and may then request that the item be place on the agenda of the next departmental faculty meeting of the program for discussion and recommendations. During Internships: 1. Notify the school of residence address and telephone number. 2. Follow the policies and procedures of the facility. Students are expected to follow the assigned work schedules and the learning experiences provided by the Clinical Instructor (CI). 3. Follow the dress code policies of the facility. 4. Observe the holiday of the facility and not the school, unless otherwise notified. 5. Notify the CI at the facility and the DCE at the school of absence greater than one day for any reason from a clinical internship. Students are allowed up to one day of absence during the long term EPA. This day is to be used only for illness and should not be considered as a personal day. Each additional day missed for illness or another approved reason must be made up during the current internship. Excessive absences may require an additional internship. The DCE will evaluate and recommend the length of time. If a student is hospitalized, has surgery, becomes pregnant, or develops a medical condition requiring bed rest, the student must have a medical release to begin or return to full clinical activities. 6. Do not request time off during clinical internships for job interviews or personal days. 7. Maintain responsibility for seeing that a Progress Report form is completed for each clinical internship. The CI must complete the narrative pages and the Visual Analog Scale. Both the student and the CI are required to sign the form indicating that both parties have reviewed it. The Progress Report must be returned to the school within one week following completion of the affiliation. The report may be mailed to the EPA Policies8

56 school or hand delivered by the student. If the Progress Report is hand delivered, the clinical instructor must place the report in an envelope and sign across the seal of the envelope and return it to the student. 8. Complete a Physical Therapist Student Evaluation: Clinical Experience and Clinical Instruction from APTA for each facility. Return these signed forms to the DCE within one week of completion of the affiliation. The Center Coordinator for Clinical Education (CCCE) at the facility may also have a form for the student to complete which is particular to the facility. Students are encouraged to share this written feedback with their CI and/or the CCCE. The Department/DCE will: 1. Assign students to EPAs dependent on availability of clinical internship sites. Completion of course work does not guarantee that a student will be provided an internship at a specific time period or at a particular facility. 2. Place students only in facilities where signed agreements exist. 3. Not place students in facilities where any real or potential conflict of interest exists. Some examples (not all inclusive) of conflict of interest are: previous paid employment in the physical therapy department, ownership of the clinic by a blood relative or relative by marriage, contract for future employment. 4. Attempt to visit students during internship periods. This is done, however, within the constraints of available faculty and travel funds. DCE from schools that are members of the Texas Consortium, Inc. may also make student visits. If a site visit is not made, a telephone conference will be arranged. If a specific problem arises with a student at any time during an internship period, every effort will be made by the DCE to visit that particular facility. CIs or students are urged to call the DCE if any problem arises. NEEDLE STICK POLICY/EMERGENCY CARE For protection from the adverse effects of exposure to body fluids and to minimize the risk of infection from blood-borne pathogens, the student should follow the policies and procedures outlined by the clinical facility. To minimize the risk of infection from blood-borne pathogens, prophylactic treatment may need to be administered within a 2-hour time frame in order for effective treatment to be dispensed. All costs incurred for medical care is the responsibility of the student. Also, if medical care and/or treatment is deemed necessary in case of an emergency, illness or injury while participating in an EPA, the student will be responsible for all costs incurred. STANDARD PRECAUTIONS In compliance with the Occupational Safety and Health Act (OSHA), as well as requirements established by most clinical facilities, all students are required to participate in education of standard precautions and blood-borne pathogens prior to their participating in any EPAs. This training is provided in Introduction to Clinical Diagnosis and Management I & V classes. EPA Policies9

57 DRUG SCREENING It is the policy of the Department of Physical Therapy at Hardin-Simmons University that students who are assigned to clinical facilities that require drug screens prior to starting the clinical experience comply with the clinical facility s policy. The student will be responsible for payment of the cost of this screen at the time of testing unless the clinical facility has agreed, in advance, to do so. A student with a positive drug screen will not be allowed to participate in the clinical component of the course at the assigned facility or any other facility. If the student feels the results of the test(s) are a false positive, s/he must have the test(s) repeated at his/her own cost. The student who tests positive on a repeat drug screen will be required to withdraw from all clinical education courses with a grade of withdraw passing. At that time, the student will be required to complete, at the student s expense, chemical dependency evaluation and treatment, or other forms of remediation, as recommended by the drug assessment. The Department of Physical Therapy at Hardin-Simmons University encourages students to seek assistance voluntarily and expects them to assume responsibility for their personal and professional conduct. Any student with a positive drug screen shall be suspended from all clinical courses. In order to be re-admitted to clinical courses, the student will be required to provide documentation of successful treatment along with documentation of a negative drug screen to the Department Head of Physical Therapy at Hardin-Simmons University. The student may continue with the academic component of the program while undergoing appropriate treatment with the stipulation that the student provides documentation of on-going treatment to the Department Head on monthly basis. Random drug screens may be required as a component of the recovering process. CRIMINAL BACKGROUND SCREEN Prior to beginning an EPA, the facility may require a Criminal Background Screen of the student. Some facilities may pay for this service, however, the student should expect to incur this expense. If a student has a significant criminal background screen or a current conviction, as identified by the Executive Council of Physical Therapy and Occupational Therapy Examiners, the student will not be allowed to go to any clinical facility. Any student who is convicted of a criminal offense during the PT program must notify the VP of Academic Affairs and the Department Head of Physical Therapy within three days of the conviction. Significant background screen or current conviction means a conviction for any matter listed in the Texas Physical Therapy Practice Act, Title 3, Subtitle H, Chapter , Occupations Code. A student with a significant criminal background screen will be required to withdraw from the program. A student may be considered for re-instatement if the Executive Board of Physical Therapy and Occupational Therapy Examiners issues a declaratory order stating the individual may be eligible for initial licensure after program completion. EPA Policies10

58 POLICY ON IMMUNIZATION & CPR REQUIREMENTS AND DOCUMENTS Students will be required to obtain tuberculosis screening (PPD) annually in order to participate in EPAs. The PPD can be obtained from the local city-county health department or will be administered and read by the Hardin-Simmons University nurse. If this screening is positive or the student has had a positive reaction in the past, an annual chest X-ray is mandatory prior to beginning the EPAs. Expenses for both the PPD and/or chest X-ray are the responsibility of the student. Additionally, students must show proof of immunization or positive blood titer for measles, mumps, and rubella. Evidence that the student has either had varicella (chicken pox), received the immunization or has a positive blood titer is required by numerous clinical sites. It is highly recommended that each student (if they have not already done so) obtain the Hepatitis B vaccine series. Students who do not receive this series of vaccinations will be required to sign a waiver while attending EPAs. The Hepatitis B vaccinations can be obtained through the local city-county health department at reasonable cost. The student is responsible for: 1. Maintaining all current immunizations/screening as required by EPA sites. 2. Obtaining documentation of any subsequent immunizations/screening performed on the immunization record. 3. Presenting the record to the CCCE or CI on the first day of each EPA as written proof of current immunization status. 4. Complying with any additional requirements set forth by a clinical facility, including the cost of any additional tests or immunizations. BASIC CPR CERTIFICATION All students are required to show proof of current certification in Basic CPR. Classes will be scheduled during the second semester for certification, which will meet the requirements for EPAs during the remaining semesters while enrolled in the PT program. COMPLAINTS AGAINST HSU DEPARTMENT OF PHYSICAL THERAPY If a Clinical Site has a complaint against the Department of Physical Therapy at HSU, please file your complaint in the form of a letter to: Department of Physical Therapy, 2200 Hickory, HSU Box 16065, Abilene, TX The Department Head will respond to your complaint within 14 business days. The complaint will be maintained in a file in the Director s office for a period of 7 years. Revised: 6/06 EPA Policies11

59 EPA Policies12

60 Notification of the Need for Remediation at the Clinical Site Name of Student~ Date Clinical CIICCCE PT Course Number ---- I have been notified on this date that I am not meeting the standards of the facility. understand that I am in jeopardy of failing this internship at this site due to the following reason(s): The following plan and time frame has been established for remediation: Student's Signature DCE's Signature CCCE/CI Signature *Remediation does not guarantee passing at this clinical. Grading will be determined based on criteria established in the course syllabus.

61 Notification of Dismissal from a Clinical Site Name of Student ~ Clinical CI/CCCE DCE PT Course Number I have been notified on this date that I am not meeting the standards of the facility and am being dismissed for the following reason(s): o o o If after discussion between the Director of Clinical Education, CCCE and the CI it is detennined that the student will not be able to successfully complete the EPA at that facility. If the student, in consultation with the Director of Clinical Education, determines that it is in the student's best interest to discontinue the EPA. Ifpersonnel at the clinical site determine that the student poses an immediate threat or danger to personnel or to the quality ofmedical services. Also, the student may be removed for unprofessional behavior or if performance is unsatisfactory. Student's Signature DCE's Signature CCCE/CI Signature Attachment: Plan and time frame for remaining at clinical site

62 INTRODUCTION EXPERIENTIAL PROFESSIONAL ACTIVITIES (EPA) POLICIES AND PROCEDURES Supervised Experiential Professional Activities (EPAs) are an integral component of the professional educational program to help apply theories and procedures learned in the classroom setting to the professional practice of physical therapy. Full-time EPAs begin with a three-week block during summer I and subsequent EPAs continue throughout the program. The Department of Physical Therapy maintains contracts with a wide variety of professional settings to provide these experiences for the student. The purpose of the EPA is to provide the opportunity for the development of sufficient skill for safe and effective entry into the practice of physical therapy. Initially, a clinical instructor will closely supervise the EPA. Increasing responsibility will be given with each affiliation so that by the end of the professional education, the student should be functioning with minimal supervision. The information, which follows, explains the clinical curriculum, the responsibilities of those involved, and the policies and procedures. Completion of the requirements for the EPA phase of the professional curriculum is the student s responsibility. The HSU PT faculty monitors EPA policies and procedures. TITLES USED Director of Clinical Education (DCE) The academic program faculty member who is responsible for the EPA portion of the professional program. (This person is also known as the Academic Coordinator of Clinical Education (ACCE) at some professional physical therapy education programs.) Center Coordinator of Clinical Education (CCCE) The person at the contracted facility who is in charge of physical therapy education programs for the facility. This person may or may not be a clinical instructor. Clinical Instructor (CI) The physical therapist that directly supervises and evaluates the student during the EPA. EPA Students may only complete EPAs at assigned facilities which have a contract with HSU for providing EPA experiences for the students. A listing of the current facilities is available from the Director of Clinical Education. The Director of Clinical Education selects clinics based on the variety of experiences that they provide, staff expertise, and other factors. Suggestions from the students for future site development are encouraged and may be addressed to the Director of Clinical Education. It is the responsibility of the Director of Clinical Education, and not the student, to make contact with potential EPA sites. Clinical Site Information Forms (CSIF) are maintained in binders in the departmental work room for student reference. Each file includes experiences available, hours, locations, to whom to report, staffing, financial assistance, housing information, dress code, directions, etc. Feedback from students who have previously affiliated with the facility is also included. EPA Policies1

63 EVALUATION OF STUDENT EPA PERFORMANCE Each student will be evaluated using the PT MACS: Physical Therapist Manual for the Assessment of Clinical Skills. Students are each required to purchase and maintain their copy of the PT MACS and will be required to have documented entry level mastery (as recorded in the PT MACS by the clinical instructors [CIs]) of all skills specified in order to complete clinical affiliations. The PT MACS provides specific goals to work toward during the EPAs and documents progress toward competent practice. Formal training in the use of the PT MACS will be provided, but students should read the instructions in the PT MACS periodically for review. Remember, these are the MINIMUM PERFORMANCES REQUIRED; it is expected that the student will attain entry-level skills while on his/her clinical rotations. PHYSICAL THERAPIST STUDENT EVALUATION: CLINICAL EXPERIENCE AND CLINICAL INSTRUCTION Clinical facilities and CIs will need feedback on their performance in providing information, supervision and learning experiences. The APTA Physical Therapist Student Evaluation: Clinical Experience and Clinical Instruction is the form used for this purpose. In addition, each clinical site may have its own form. The Physical Therapist Student Evaluation: Clinical Experience and Clinical Instruction must be completed by the student prior to leaving the EPA, shared with the CI, signed by both the student and CI, and returned to the Director of Clinical Education. These forms are not meant to be threatening, but to facilitate open, honest, and constructive evaluation of the EPA experience. Students need to be honest in evaluating so that others may benefit from their experience. EPA EXPECTATIONS: Specific criteria are as follows: 1. In the 1 st Edition of the PT MACS, skills 1-11 are essential for professional practice and, therefore, required to be checked off ( ) as entry level on 3 of the 5 off-site clinicals. 2. #1 Commitment to Learning #2 Interpersonal Skills #3 Communication Skills: Oral and Written #4 Effective Use of Time and Resources #5 Use of Constructive Feedback #6 Problem Solving #7 Professionalism #8 Responsibility #9 Critical Thinking #10 Stress Management #11 Safety During Patient Management 3. If a specific PT MACS skill (#1-#19) is not completed at the end of EPA VI, the faculty will determine the action to be taken on a case-by-case basis. 4. The faculty retains the right to review the status of the PT MACS skill(s) completion for the purpose of additional EPA assignment if necessary. EPA Policies2

64 GRADING POLICIES The Program in Physical Therapy reserves the right to assign the grade to students. Refer to each EPA course syllabus for specific criteria for earning a passing grade. Possible grades for Clinical Education courses are: A, B, C as noted on the syllabus criteria. F Fail Any one of these examples may result in a grade of F: a. Significant number of the grading criteria were not met even though the necessary experiences were available or, b. Student demonstrated continuing deficiencies in areas of professional behavior or issues involving safety. I Incomplete These are examples which may result in a grade of I: a. Student completed a successful internship but learning experiences or patient populations were not adequate to complete the grading criteria or, b. Student had to withdraw due to illness or personal emergency or, c. Student was withdrawn at the discretion of the Director of Clinical Education and the Department Head. d. The number of NI s exceeds those allowed to meet A/B/C grade criteria. WP Withdraw Passing Used at the discretion of the DCE with faculty consultation for voluntary withdrawal from the program or in the event of significant absence from seminars or time lost during the internship due to illness or personal emergency. 1. Students must receive a passing grade of A, B, or C in clinical coursework. If a failing grade is earned, the student will be terminated from the program. 2. If a student earns a grade of I (Incomplete), the provisions for the removal of the Incomplete will be given to the student in writing. Grades of Incomplete in clinical internship courses will require additional clinical time to remove the Incomplete generally after the completion of all other clinical rotations. 3. If a student earns a grade of WP (Withdraw Passing), requirements to re-enroll in the course will be determined by the DCE. The student will be out-of-sequence and future internship scheduling will be determined by the DCE. EPA REMEDIATION/ DISCONTINUANCE A student, who in the eyes of the Clinical Instructor, is not progressing to the extent that he/she may not meet the minimal requirements for that affiliation, may need to develop a remediation plan as outlined below. Procedures for EPA Remediation: 1. The student must be notified of the potential for remediation from the clinical facility when he/she is failing to meet criteria. This should occur by midterm of the affiliation. 2. The student, in agreement with the CI, must complete a written plan with time frames for remaining at the clinical site and successfully completing certain skills. (See attached Remediation form.) EPA Policies3

65 3. If the terms of the plan are not met in the specified time, the internship will be terminated and the student will receive a grade of I (Incomplete), F (fail), or WP (Withdraw Passing) as determined to be appropriate by the DCE with faculty consensus. 4. Copies of the notification will be provided for the student, the clinical facility and the Department of Physical Therapy at HSU. Dismissal From a Clinical Site: A student may be removed from the clinical setting for the following reasons: 1. If after discussion between the Director of Clinical Education, CCCE and the CI it is determined that the student will not be able to successfully complete the EPA at that facility. 2. The student, in consultation with the Director of Clinical Education, determines that it is in the student s best interest to discontinue the EPA. 3. Personnel at the clinical site determine that the student poses an immediate threat or danger to personnel or to the quality of medical services. Also, the student may be removed for unprofessional behavior or if performance is unsatisfactory. Procedures for Dismissal from a Clinical Site: 1. Notification of dismissal can be extended at any time if the student exhibits unprofessional behaviors or is an immediate threat of danger to patients, other personnel or acts in a manner that threatens the quality of medical services. The notice must be made both verbally and in writing on the Notification of Dismissal from a Clinical Site form (attached). 2. Copies of the notification will be provided for the student, the clinical facility, and the Department of Physical Therapy at HSU. 3. A consensus of the HSU PT Departmental faculty will be required for decisions regarding whether the student will be allowed to continue in the Physical Therapy program or placed in an additional clinical site. APPEALS OF CLINICAL EDUCATION GRADES AND POLICIES Appeals can be made following the same guidelines as those for other courses and policies as listed in the Graduate Bulletin under Grade Appeal Process. COST OF EPAs Students should be prepared to incur additional expenses beyond tuition for EPAs including mandatory background checks and drug screens as required by many clinical sites. Since EPA assignments may be out-of-town or even out-of-state, students may need to maintain living arrangements here as well as pay for accommodations during the EPA. It will be the responsibility of the student to provide their own travel expenses to/from EPAs and to secure out-of-town housing. Clinical facilities may provide or be able to assist in obtaining housing. The personal situation of the student will be taken into consideration when making clinical assignments. HEALTH REQUIREMENTS FOR EPAs EPA Policies4

66 It is the student s responsibility to keep immunizations current and to comply with any other health requirements/documentation specified by the clinical facility to which they are assigned. Students must have health insurance while on EPAs. The student will provide a copy of these records for the departmental file. STUDENT PROFESSIONAL LIABILITY INSURANCE All students are required to have malpractice/professional liability insurance coverage. Purchase of this insurance under a group policy is handled by HSU and is a part of the registration fee each year. REQUIRED APPEARANCE FOR EPAs Unless otherwise notified, the following personal behavior and attire is mandatory during any patient contact: 1. Students will wear professional clothing: men will normally wear dress slacks, dress shirt or golf shirt with collar; women will wear dress slacks/skirt and blouse or shirt that can be tucked in and avoids exposure of breasts, midriffs, or buttocks. A lab coat and/or scrubs may be required at certain facilities. 2. Sensible shoes with closed toes and non-slip soles are appropriate. Athletic shoes, which are multi-colored, sandals, flip-flops, and high heels are not considered appropriate for the clinic. 3. HSU name badge (unless facility requires a hospital name badge). 4. Nails must be trimmed and long hair secured off face for safety in treating patients. 5. No large or excessive jewelry. 6. Earrings may only be worn in the earlobe; no multiple earrings. 7. Avoid excessive colognes, perfumes, and aftershaves. 8. Good personal hygiene. 9. No tattoos visible when treating patients. Students assigned to a clinical facility that requires a different personal and/or dress code, must follow that facility s requirements as noted in the EPA Information File. ABSENCE AND TARDINESS Tardiness or absence during an EPA or over a series of EPAs may result in an I (Incomplete) grade and a requirement for additional EPA assignment(s). Attendance at all scheduled EPAs is MANDATORY. An unexcused absence is reason for disciplinary action with possible termination from the program. In case of emergency or illness, an excused absence can be granted according to the following procedures. The student must: 1. Notify the CI or CCCE (according to facility policy) PRIOR to scheduled daily arrival time giving the reason necessitating the absence. The CI/CCCE will determine if the reason is appropriate for an excused absence; 2. If absences exceed one day per long term EPA, the missed time must be made up during that EPA at the discretion of the CI/CCCE; EPA Policies5

67 3. The makeup time will be determined by the CI/CCCE (according to facility policy) at a time deemed convenient for the clinic. Tardiness is to be avoided. Students must notify the CI or CCCE (according to the facility s policy) prior to the normal scheduled arrival time. EPA SITUATIONS REQUIRING DIRECTOR OF CLINICAL EDUCATION NOTIFICATION Most situations involving EPAs (e.g. sick, tardy, extra clinical days, daily concerns) can be handled between CI and student. However, the student MUST notify the Director of Clinical Education IMMEDIATELY if any of the following occur: 1. An extended absence is required due to sickness, injury, personal reasons, etc. 2. A significant on-the-job injury occurs that requires medical care. 3. An incident occurs that has potential malpractice/liability implications. 4. Problems arise with the EPA assignment that cannot be worked out with the clinical instructor. REPORTING TO EPA ASSIGNMENT Students are responsible for checking the EPA Information File for procedures regarding to whom and when to report before leaving for any EPA assignment. Students are required to write the clinical facility four to six weeks prior to the beginning of the affiliation to confirm the assignment and other arrangements. The student is then required to follow up with a phone call to the facility one week prior to beginning the EPA. Documentation of these requirements is to be provided to the Director of Clinical Education. Failure to meet the requirements may result in the cancellation of the EPA. MONITORING STUDENT PROGRESS DURING EPA The Director of Clinical Education calls or visits each student during each full-time EPA to discuss progress with the student and the CI. Mid-term evaluations will be made using the Progress Report in the PT MACS or a form provided by the Director of Clinical Education. PROCEDURES FOR ASSIGNMENT TO EPA SITES Availability of Sites: EPA sites are surveyed annually to determine the number of available student positions. Due to the variety of EPAs needed; it cannot be guaranteed that the student will have an EPA in a local facility. Students should plan on doing at least one EPA out of town. All effort will be made to take into account the personal situation of each student. It is in the student s best interest to experience numerous approaches to treatment, varied clinical settings, culturally diverse patient populations, and different means of documentation. EPA Policies6

68 Preliminary Activities: Through periodic counseling with the student and review of the PT MACS, the Director of Clinical Education will assist the student in identifying clinics available to meet the needed skill exposure. The Department cannot guarantee that students will be placed in the setting of their choice. ASSIGNMENT OF EPA SITES The Director of Clinical Education makes EPA assignments with the primary goal of providing each student with sufficient opportunity to attain mastery of entry-level skills in a variety of clinical settings. Occasionally, an EPA site will cancel the EPA on very short notice due to unforeseen circumstances. In such circumstances, the Director of Clinical Education will assist the student in identifying a suitable and timely alternative placement. Thus, the department cannot assume liability for delays in completion of the program or other losses/inconveniences sustained by the student under these circumstances. The Department will make reasonable and concerted efforts to find alternative placements when extenuating circumstances have precluded the student s participation in the experience. The Department believes it is not in the student s best interest to be placed in an EPA in which they plan to be employed following graduation. Thus students who are under contract or who anticipate working at a specific facility following graduation will not be assigned an EPA at that facility. RESPONSIBILITIES FOR THOSE INVOLVED IN EPAs The following are responsibilities, which are in addition to those stated elsewhere: The Facility must: 1. Provide learning experiences as available and appropriate for the student at that time; based on objectives of the Department, facility and student. 2. Provide supervision and counseling of student and document student s status using forms provided. 3. Coordinate, communicate, and report student s status to the Department by way of the designated facility Clinical Coordinator or Clinical Instructor. The Student must: Before Internships: 1. Have an overall grade point average of 3.0 based on a 4.0 grading scale at the end of the second fall semester of the curriculum. 2. Attend all clinical education seminars prior to participation in the scheduled clinical internship. Seminars and internships may occur in subsequent semesters. The actual course grade will include seminar participation and attendance as well as the internship requirements. 3. Have personal health insurance coverage before registering for any clinical education course and must furnish proof of this insurance. The University, as a part of the course fees, provides student liability insurance. The coverage is not valid unless a student is officially enrolled in the University. Student liability coverage is tied to actual course work and does not cover any students during part time or full time employment activities. EPA Policies7

69 4. Maintain responsibility for transportation, living arrangements, living expenses and telephone expenses related to clinical internships. 5. Meet the immunization requirements of the school and the facility. The Director of Clinical Education (DCE) will inform students of general health requirements and other requirements specific to a facility. The facility has the right to bar a student from clinical activities if proof of meeting all health requirements cannot be provided. Health forms, pictures and biographical data forms, current CPR certification must be submitted by the completion of the 2nd semester. 6. Have valid CPR certification during all clinical internships. Students will not be given time off from internships to revalidate the certificate. 7. Read the facility folder for the sites to which they have been assigned and respond to any specific request made by the facility that has been approved by the program. 8. Submit a written request to the DCE, along with appropriate documentation of inability to begin a scheduled internship, as soon as possible but prior to the starting date to request postponement of the internship. 9. Meet all requirements of the assigned clinical facility. Drug screens and/or a criminal background check may be required by clinical facilities. If the student is unable to be cleared on these requirements, the student may not be eligible to continue in the program. Expense for such testing/screening will be the student s responsibility. 10. Direct any request regarding scheduling of internships, exceptions for personal reasons or other requests that may affect the Clinical Education Policies to the DCE. The DCE may ask that the student put the request in writing and may then request that the item be place on the agenda of the next departmental faculty meeting of the program for discussion and recommendations. During Internships: 1. Notify the school of residence address and telephone number. 2. Follow the policies and procedures of the facility. Students are expected to follow the assigned work schedules and the learning experiences provided by the Clinical Instructor (CI). 3. Follow the dress code policies of the facility. 4. Observe the holiday of the facility and not the school, unless otherwise notified. 5. Notify the CI at the facility and the DCE at the school of absence greater than one day for any reason from a clinical internship. Students are allowed up to one day of absence during the long term EPA. This day is to be used only for illness and should not be considered as a personal day. Each additional day missed for illness or another approved reason must be made up during the current internship. Excessive absences may require an additional internship. The DCE will evaluate and recommend the length of time. If a student is hospitalized, has surgery, becomes pregnant, or develops a medical condition requiring bed rest, the student must have a medical release to begin or return to full clinical activities. 6. Do not request time off during clinical internships for job interviews or personal days. 7. Maintain responsibility for seeing that a Progress Report form is completed for each clinical internship. The CI must complete the narrative pages and the Visual Analog Scale. Both the student and the CI are required to sign the form indicating that both parties have reviewed it. The Progress Report must be returned to the school within one week following completion of the affiliation. The report may be mailed to the EPA Policies8

70 school or hand delivered by the student. If the Progress Report is hand delivered, the clinical instructor must place the report in an envelope and sign across the seal of the envelope and return it to the student. 8. Complete a Physical Therapist Student Evaluation: Clinical Experience and Clinical Instruction from APTA for each facility. Return these signed forms to the DCE within one week of completion of the affiliation. The Center Coordinator for Clinical Education (CCCE) at the facility may also have a form for the student to complete which is particular to the facility. Students are encouraged to share this written feedback with their CI and/or the CCCE. The Department/DCE will: 1. Assign students to EPAs dependent on availability of clinical internship sites. Completion of course work does not guarantee that a student will be provided an internship at a specific time period or at a particular facility. 2. Place students only in facilities where signed agreements exist. 3. Not place students in facilities where any real or potential conflict of interest exists. Some examples (not all inclusive) of conflict of interest are: previous paid employment in the physical therapy department, ownership of the clinic by a blood relative or relative by marriage, contract for future employment. 4. Attempt to visit students during internship periods. This is done, however, within the constraints of available faculty and travel funds. DCE from schools that are members of the Texas Consortium, Inc. may also make student visits. If a site visit is not made, a telephone conference will be arranged. If a specific problem arises with a student at any time during an internship period, every effort will be made by the DCE to visit that particular facility. CIs or students are urged to call the DCE if any problem arises. NEEDLE STICK POLICY/EMERGENCY CARE For protection from the adverse effects of exposure to body fluids and to minimize the risk of infection from blood-borne pathogens, the student should follow the policies and procedures outlined by the clinical facility. To minimize the risk of infection from blood-borne pathogens, prophylactic treatment may need to be administered within a 2-hour time frame in order for effective treatment to be dispensed. All costs incurred for medical care is the responsibility of the student. Also, if medical care and/or treatment is deemed necessary in case of an emergency, illness or injury while participating in an EPA, the student will be responsible for all costs incurred. STANDARD PRECAUTIONS In compliance with the Occupational Safety and Health Act (OSHA), as well as requirements established by most clinical facilities, all students are required to participate in education of standard precautions and blood-borne pathogens prior to their participating in any EPAs. This training is provided in Introduction to Clinical Diagnosis and Management I & V classes. EPA Policies9

71 DRUG SCREENING It is the policy of the Department of Physical Therapy at Hardin-Simmons University that students who are assigned to clinical facilities that require drug screens prior to starting the clinical experience comply with the clinical facility s policy. The student will be responsible for payment of the cost of this screen at the time of testing unless the clinical facility has agreed, in advance, to do so. A student with a positive drug screen will not be allowed to participate in the clinical component of the course at the assigned facility or any other facility. If the student feels the results of the test(s) are a false positive, s/he must have the test(s) repeated at his/her own cost. The student who tests positive on a repeat drug screen will be required to withdraw from all clinical education courses with a grade of withdraw passing. At that time, the student will be required to complete, at the student s expense, chemical dependency evaluation and treatment, or other forms of remediation, as recommended by the drug assessment. The Department of Physical Therapy at Hardin-Simmons University encourages students to seek assistance voluntarily and expects them to assume responsibility for their personal and professional conduct. Any student with a positive drug screen shall be suspended from all clinical courses. In order to be re-admitted to clinical courses, the student will be required to provide documentation of successful treatment along with documentation of a negative drug screen to the Department Head of Physical Therapy at Hardin-Simmons University. The student may continue with the academic component of the program while undergoing appropriate treatment with the stipulation that the student provides documentation of on-going treatment to the Department Head on monthly basis. Random drug screens may be required as a component of the recovering process. CRIMINAL BACKGROUND SCREEN Prior to beginning an EPA, the facility may require a Criminal Background Screen of the student. Some facilities may pay for this service, however, the student should expect to incur this expense. If a student has a significant criminal background screen or a current conviction, as identified by the Executive Council of Physical Therapy and Occupational Therapy Examiners, the student will not be allowed to go to any clinical facility. Any student who is convicted of a criminal offense during the PT program must notify the VP of Academic Affairs and the Department Head of Physical Therapy within three days of the conviction. Significant background screen or current conviction means a conviction for any matter listed in the Texas Physical Therapy Practice Act, Title 3, Subtitle H, Chapter , Occupations Code. A student with a significant criminal background screen will be required to withdraw from the program. A student may be considered for re-instatement if the Executive Board of Physical Therapy and Occupational Therapy Examiners issues a declaratory order stating the individual may be eligible for initial licensure after program completion. EPA Policies10

72 POLICY ON IMMUNIZATION & CPR REQUIREMENTS AND DOCUMENTS Students will be required to obtain tuberculosis screening (PPD) annually in order to participate in EPAs. The PPD can be obtained from the local city-county health department or will be administered and read by the Hardin-Simmons University nurse. If this screening is positive or the student has had a positive reaction in the past, an annual chest X-ray is mandatory prior to beginning the EPAs. Expenses for both the PPD and/or chest X-ray are the responsibility of the student. Additionally, students must show proof of immunization or positive blood titer for measles, mumps, and rubella. Evidence that the student has either had varicella (chicken pox), received the immunization or has a positive blood titer is required by numerous clinical sites. It is highly recommended that each student (if they have not already done so) obtain the Hepatitis B vaccine series. Students who do not receive this series of vaccinations will be required to sign a waiver while attending EPAs. The Hepatitis B vaccinations can be obtained through the local city-county health department at reasonable cost. The student is responsible for: 1. Maintaining all current immunizations/screening as required by EPA sites. 2. Obtaining documentation of any subsequent immunizations/screening performed on the immunization record. 3. Presenting the record to the CCCE or CI on the first day of each EPA as written proof of current immunization status. 4. Complying with any additional requirements set forth by a clinical facility, including the cost of any additional tests or immunizations. BASIC CPR CERTIFICATION All students are required to show proof of current certification in Basic CPR. Classes will be scheduled during the second semester for certification, which will meet the requirements for EPAs during the remaining semesters while enrolled in the PT program. COMPLAINTS AGAINST HSU DEPARTMENT OF PHYSICAL THERAPY If a Clinical Site has a complaint against the Department of Physical Therapy at HSU, please file your complaint in the form of a letter to: Department of Physical Therapy, 2200 Hickory, HSU Box 16065, Abilene, TX The Department Head will respond to your complaint within 14 business days. The complaint will be maintained in a file in the Director s office for a period of 7 years. Revised: 6/06 EPA Policies11

73 EPA Policies12

74 Hardin-Simmons University Department of Physical Therapy Graduate Studies in Physical Therapy Policies & Procedures Acknowledgement Student Click here to enter text. By my signature I acknowledge that I have read and understand the Guidelines for Clinical Instructors as outlined by APTA and the EPA Policies and Procedures pertaining to the DPT students of Hardin-Simmons University. CI Signature Click here to enter a date. Date Pease return (within the student s first week) to Mary Lou Garrett PT, DPT, PCS Fax~ ~~ mgarrett@hsutx.edu Box / Abilene, TX /

75 GUIDELINES FOR CLINICAL INSTRUCTORS 1.0 THE CLINICAL INSTRUCTOR (CI) DEMONSTRATES CLINICAL COMPETENCE, AND LEGAL AND ETHICAL BEHAVIOR THAT MEETS OR EXCEEDS THE EXPECTATIONS OF MEMBERS OF THE PROFESSION OF PHYSICAL THERAPY. 1.1 One year of clinical experience is preferred as minimal criteria for serving as the CI. Individuals should also be evaluated on their abilities to perform CI responsibilities The CI demonstrates a desire to work with students by pursuing learning experiences to develop knowledge and skills in clinical teaching. 1.2 The CI is a competent physical therapist or physical therapist assistant The CI demonstrates a systematic approach to patientjclient care using the patient/client management model described in the Guide to Physical Therapist Practice The CI uses critical thinking in the delivery of health services Rationale and evidence is provided by: The physical therapist for examination, evaluation, diagnosis, prognosis, interventions, outcomes, and reexaminations The physical therapist assistant for directed interventions, data collection associated with directed interventions, and outcomes The CI demonstrates effective time-management skills The CI demonstrates the core values (accountability, altruism, compassion/caring, excellence, integrity, professional duty, and social responsibility) associated with professionalism in physical therapy. 1.3 The CI adheres to legal practice standards The CI holds a valid license, registration, or certification as required by the state in which the individual provides physical therapy services The CI provides physical therapy services that are consistent with the respective state/jurisdictional practice act and interpretive rules and regulations The CI provides physical therapy services that are consistent with state and federal legislation, including, but not limited to, equal opportunity and affirmative action policies, HIPAA, Medicare regulations regarding reimbursement for patient/client care where students are involved, and the ADA The physical therapist is solely responsible for ensuring the patient/client is aware of the student status of any student involved in providing physical therapy services. 39

76 1.4 The CI demonstrates ethical behavior The CI provides physical therapy services ethically as outlined by the clinical education site policy and the APTA Code ofethics, Standards ofethical Conduct for the Physical Therapist Assistant, Guide for Professional Conduct, Guide for Conduct ofthe Affiliate Member, and Guide to Physical 711erapist Practice. 2.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE COMMUNICATION SKILLS. 2.1 The CI uses verbal, nonverbal, and written communication skills and information technology to clearly express himself or herself to students and others The CI defines performance expectations for students The CI and student(s) collaborate to develop mutually agreed-on goals and objectives for the clinical education experience The CI provides feedback to students The CI demonstrates skill in active listening The CI provides clear and concise communication. 2.2 The CI is responsible for facilitating communication The CI encourages dialogue with students The CI provides time and a place for ongoing dialogue to occur The CI initiates communication that may be difficult or confrontational The CI is open to and encourages feedback from students, clinical educators, and other colleagues. 3.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE BEHAVIOR, CONDUCT, AND SKILL IN INTERPERSONAL RELATIONSHIPS. 3.1 The CI forms a collegial relationship with students The CI models behaviors and conduct, and instructional and supervisory skills that are expected of the physical therapist!physical therapist assistant and demonstrates an awareness of the impact of this role modeling on students The CI promotes the student as a colleague to others The CI demonstrates cultural competence with respect for and sensitivity to individual and cultural differences The CI is willing to share his or her strengths and weaknesses with students. 40

77 3.2 The CI is approachable by students The CI assesses and responds to student concerns with empathy, support, or interpretation, as appropriate. 3.3 The CI interacts with patientsjclients, colleagues, and other health care providers to achieve identified goals. 3.4 The CI represents the physical therapy profession positively by assuming responsibility for career and self-development and demonstrates this responsibility to the students Activities for development may include, but are not limited to, continuing education courses, journal clubs, case conferences, case studies, literature review, facility sponsored courses, post-professionaljentry-level education, area consortia programs, and active involvement in professional associations, including APT A. 4.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE INSTRUCTIONAL SKILLS. 4.1 The CI collaborates with students to plan learning experiences Based on a plan, the CI implements, facilitates, and evaluates learning experiences with students Learning experiences should include both patientjclient interventions and patientjclient practice management activities. 4.2 The CI demonstrates knowledge of the student's academic curriculum, level of didactic preparation, current level of performance, and the goals of the clinical education experience. 4.3 The CI recognizes and uses the entire clinical environment for potential learning experiences, both planned and unplanned. 4.4 The CI integrates knowledge of various learning styles to implement strategies that accommodate students' needs. 4.5 The CI sequences learning experiences to promote progression of the students' personal and educational goals The CI monitors and modifies learning experiences in a timely manner based on the quality of the student's performance. 5.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE SUPERVISORY SKILLS. 5.1 The CI supervises the student in the clinical environment by clarifying goals, objectives, and expectations. 41

78 5.1.1 The CI presents clear performance expectations to students at the beginning and throughout the learning experience Goals and objectives are mutually agreed on by the CI and student(s). 5.2 Feedback is provided both formally and informally To provide student feedback, the CI collects information through direct observation and discussion with students, review of the students' patient/client documentation, available observations made by others, and students' self-assessments The CI provides frequent, positive, constructive, and timely feedback The CI and students review and analyze feedback regularly and adjust the learning experiences accordingly. 5.3 The CI performs constructive and cumulative evaluations of the students' performance The CI and students both participate in ongoing formative evaluation Cumulative evaluations are provided at least at midterm and at the completion of the clinical education experience and include student self-assessments. 6.0 THE CLINICAL INSTRUCTOR DEMONSTRATES PERFORMANCE EVALUATION SKILLS. 6.1 The CI articulates observations of students' knowledge, skills, and behavior as related to specific student performance criteria The CI familiarizes herself or himself with the student's evaluation instrument prior to the clinical education experience The CI recognizes and documents students' progress, identifies areas of entrylevel competence, areas of distinction, and specific areas of performance that are unsafe, ineffective, or deficient in quality Based on areas of distinction, the CI plans, in collaboration with the CCCE and the ACCE/DCE when applicable, activities that continue to challenge students' performance Based on the areas identified as inadequate, the CI plans, in collaboration with the CCCE and ACCE/DCE when applicable, remedial activities to address specific deficits in student performance. 6.2 The CI demonstrates awareness of the relationship between the academic program and clinical education site concerning student performance evaluations, grading, remedial activities, and due process in the case of student failure. 6.3 The CI demonstrates a constructive approach to student performance evaluation that is educational, objective, and reflective and engages students in self-assessment (eg, 42

79 problem identification, processing, and solving) as part of the performance evaluation process. 6.4 The CI fosters student evaluations of the clinical education experience, including learning opportunities, CI and CCCE performance, and the evaluation process. The foundation for this document is: Barr IS, Gwyer ]. Standards for Clinical Education in Physical Therapij: A Manual for Evaluation and Selection of Clinical Education Centers. Alexandria, Va: American Physical Therapy Association; 1981:3-8. Commission on Accreditation in PhYSical Therapy Education. Evaluative Criteria for Accreditation of Education Programs for the Preparation of Physical Therapists. In: Accreditation Handbook. Alexandria, Va: American Physical Therapy Association; Moore ML, Perry ]F. Clinical Education in Physical Therapy: Present StatusjFuture Needs. Alexandria, Va: American Physical Therapy Association and the Section for Education; The development ofthis document was a result of combined efforts ofthe Task Force on Clinical Education, , and the Task Force on Clinical Education, Revisions of this document are based on: 1. Guide to Physical Therapist Practice. Rev 2nd ed. Alexandria, Va: American PhYSical Therapy Association; A Normative Model of Physical Therapist Profossional Education:: Version Alexandria, Va: American Physical Therapy Association; A Normative Model ofphysical Therapist Assistant Education:: Version 99. Alexandria, Va: American PhYSical Therapy Association; Physical Therapist Clinical Performance Instrument. Physical TherapiJ Clinical Performance Instruments. Alexandria, Va: American Physical Therapy Association; Physical Therapist Assistant Clinical Performance Instrument. Physical Therapy Clinical Performance Instruments. Alexandria, Va: American Physical Therapy Association; Commission on Accreditation in Physical Therapy Education. Evaluative Criteria for Accreditation of Education Programs for the Preparation of Physical Therapists. In: Accreditation Handbook. Alexandria, Va: American Physical Therapy Association; Commission on Accreditation in Physical Therapy Education. Evaluative Criteria for Accreditation of Education Programs for the Preparation of PhYSical Therapist Assistants. In: Accreditation Handbook. Alexandria, Va: American Physical Therapy Association;

80 SELF ASSESSNIENTS FOR CLINICAL INSTRUCTORS 1.0 THE CLINICAL INSTRUCTOR (CI) DEMONSTRATES CLINICAL COMPETENCE AND LEGAL AND ETHICAL BEHAVIOR THAT MEETS OR EXCEEDS THE EXPECTATIONS OF MEMBERS OF THE PROFESSION OF PHYSICAL THERAPY. 1. Do you, as the clinical instructor (CI), have at least 1 year of clinical experience? DYes DNo D Developing 2. Do you demonstrate a desire to work with students by pursuing learning experiences to develop knowledge and skills in clinical teaching? DYes DNo D Developing 3. Do you, as the ei, demonstrate competence as a physical therapist or a physical therapist assistant by: a) Utilizing the patient/client management model in the Guide to Physical Therapist Practice to demonstrate a systematic approach to patient care? DYes DNo D Developing b) Using clinical reasoning and evidencebased practice in the delivery of health DYes DNo D Developing services? c) Providing rationale for the patient/client? Examination, evaluation, diagnosis, prognosis, interventions, outcomes, and reexaminations (PT) DYes DNo o Developing Interventions (including data collection and outcomes associated with those DYes DNo D Developing interventions) as directed and supervised by the PT and within the plan of care (PTA) d) Demonstrating effective time-management skills? DYes DNo D Developing 4. Do you, as the CI, adhere to legal practice standards? a) By holding a current license/registration/ certification as required by the physical therapy practice act in the state in which you practice? DYes DNo D Developing b) By providing physical therapy services that are consistent with your state practice act and interpretive rules and regulations? DYes rno D Developing 44

81 c) By providing physical therapy services that are consistent with state and federal legislation, including, but not limited to: Equal opportunity and affirmative action policies DYes DNo o Developing Americans With Disabilities Act (ADA) DYes DNo o Developing d) By ensuring that the patients/clients have been informed of and consent to have a student involved in providing physical therapy services? DYes DNo o Developing 5. Do you, as the Cl, demonstrate ethical behavior, as outlined by the clinical education site policy and the APT A Code of Ethics and Guide for Professional Conduct? DYes DNo o Developing 6. Do you, as the Cl, consistently demonstrate the APT A Core Values ( ion/professionalism.pdf) of accountability,* altruism,* compassion/caring,* exceuence,* integrity,* professional duty,* and social responsibility*? DYes DNo o Developing COMMENTS/pLAN: 45

82 2.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE COMMUNICATION SKILLS. 1. Do you, as the CI, use verbal, nonverbal, and written communication skills and information technology to clearly express yourself to students to: a) Define performance expectations for students? DYes DNo o Developing b) Collaborate to develop mutually agreed-on goals and objectives for the clinical education experience? DYes DNo o Developing c) Provide feedback? DYes DNo o Developing d) Demonstrate skill in active listening? DYes DNo o Developing 2. Do you, as the CI, facilitate communication by: a) Encouraging dialogue with students? DYes DNo o Developing b) Providing time and a place for ongoing dialogue to occur? DYes DNo o Developing c) Initiating communication that may be difficult or confrontational around an issue of concern? DYes DNo o Developing d) Remaining open to and encouraging feedback from students, clinical educators, and other colleagues? DYes DNo o Developing COMMENTSjPLAN: 46

83 3.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE BEHAVIOR, CONDUCT, AND SKILL IN INTERPERSONAL RELATIONSHIPS. 1. Do you, as the CI, form a collegial relationship with students? DYes DNo D Developing 2. Do you model behaviors and conduct and instructional and supervisory skills that are expected of the PT or PTA? DYes DNo D Developing 3. Do you demonstrate an understanding of the impact of your behavior and conduct as a role model for students? DYes DNo D Developing 4. Do you promote the student as a colleague to others? DYes DNo D Developing 5. Do you demonstrate respect for and sensitivity to individual differences? DYes DNo D Developing 6. Are you willing to share your strengths and weaknesses with students? DYes DNo D Developing 7. Do you, as the CI, remain approachable by assessing and responding to student concerns with empathy, support, or interpretation, as appropriate? DYes DNo D Developing B. Do you, as the CI, interact appropriately with patients, colleagues, and other health professionals to achieve identified goals? DYes DNo D Developing 9. Do you represent the physical therapy profession positively by assuming responsibility for career and self-development and demonstrate this responsibility to the student by participation in activities, such as: a) Continuing education courses? DYes DNo D Developing b) Journal dub? DYes DNo D Developing c) Case conferences? DYes DNo D Developing d) Case studies? DYes DNo D Developing e) Literature review? DYes DNo D Developing f) Facility sponsored courses? DYes DNo D Developing g) Post-entry-Ievel education? DYes DNo D Developing 47

84 h) Area consortia programs? DYes DNo D Developing i) Membership and active involvement in the profession (eg, America Physical Therapy Association) DYes DNo D Developing COMMENTSjPLAN: 48

85 4.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE INSTRUCTIONAL SKILLS. 1. Do you, as the CI, implement, facilitate, and evaluate learning experiences for students based on a plan created in collaboration with students? DYes DNo D Developing 2. Do you, as the CI, review the student's academic curriculum, level of didactic preparation, current level of performance, and the goals of the clinical education experience? DYes DNo D Developing 3. Do you include learning experiences in the patient/client mat).agement model (eg, examination, evaluation, diagnosis, prognosis, plan of care, intervention, and outcomes for the PT student; directed interventions with the plan of care for the PTA student) and practice management activities (eg, billing, staff meetings, marketing)? DYes DNo D Developing 4. Do you, as the CI, maximize learning opportunities by using planned and unplanned experiences within the entire clinical environment? DYes DNo D Developing 5. Do you, as the CI, integrate knowledge of various learning styles to implement strategies that accommodate students' needs? DYes DNo D Developing 6. Do you, as the CI, sequence learning experiences to allow progression towards the student's personal and educational goals? DYes DNo D Developing 7. Do you, as the CI, monitor and modify learning experiences in a timely manner, based on the quality of the student's performance? DYes DNo D Developing COMMENTSfPLAN: 49

86 5.0 THE CLINICAL INSTRUCTOR DEMONSTRATES EFFECTIVE SUPERVISORY SKILLS. 1. Do you, as the CI, present clear performance DYes DNo D Developing expectations to students at the beginning of and throughout the learning experience? 2. Are goals and objectives mutually agreed on by DYes DNo D Developing you and students? 3. Do you, as the CI, provide both formal and DYes DNo D Developing informal feedback? 4. To provide student feedback, do you collect information through: a) Direct observation and discussions with DYes DNo D Developing students? b) Review of the students' patient/client DYes DNo D Developing documentation? c) Available observations made by others? DYes DNo D Developing d) Students'self-assessments? DYes DNo D Developing 5. Do you, as the CI, provide feedback to students that is: a) Frequent? DYes DNo D Developing b) Positive? DYes DNo D Developing c) Constructive? DYes DNo D Developing d) Timely? DYes DNo D Developing 6. Do you, as the CI, review and analyze feedback DYes DNo D Developing regularly and adjust learning experiences accordingly? 7. Do you, as the CI, perform constructive (interim) and cumulative (final) evaluations of the students' performance by: a} Participating with the student in ongoing DYes DNo D Developing constructive evaluations? b) Providing cumulative evaluations at least at DYes DNo D Developing midterm and at the completion of the clinical education experience? c) Including student self-assessments? DYes DNo D Developing 50

87 6.0 THE CLINICAL INSTRUCTOR DEMONSTRATES PERFORMANCE EVALUATION SKILLS. 1. Do you, as the CI, familiarize yourself with the students' evaluation instrument(s) prior to the clinical education experience? DYes DNo D Developing 2. Do you, as the CI, use and articulate available information and observations when evaluating students' knowledge, skills, and behavior as related to specific performance criteria? DYes DNo D Developing 3. Do you, as the CI, recognize and document students' progress by identifying areas of: a) Entry-level competence? DYes DNo D Developing b) Exceptional performance? DYes DNo D Developing c) Unsafe or ineffective performance? DYes DNo D Developing d) Appropriate progression? DYes DNo D Developing 4. In collaboration with the CCCE and ACCEjDCE, do you plan activities that continue to challenge student performance based on areas of: a) Exceptional performance? DYes DNo D Developing b) Appropriate progression? DYes DNo D Developing c) Specific deficits? DYes DNo D Developing 5. Do you, as the CI, demonstrate awareness of the relationship between the academic program and clinical education site as it relates to: a) Student performance evaluations? DYes DNo D Developing b) Grading? DYes DNo D Developing c) Remedial activities? DYes DNo D Developing d) Due process in the case of student failure? DYes DNo D Developing 6. Do you, as the CI, demonstrate a constructive approach to student performance evaluation that is: a) Educational? DYes DNo D Developing b) Objective? DYes DNo D Developing c) Reflective? DYes DNo D Developing 52

88 d) Directed at engaging students in selfassessment? DYes DNo D Developing 7. Do you foster student evaluation of the clinical education experience, including: a) Learning opportunities? DYes DNo D Developing b) CI performance? DYes DNo D Developing c) CCCE performance? DYes DNo D Developing d) The evaluation process? DYes DNo D Developing COMMENTSjPLAN: http: AM Template.cfm?Section~Clinical&Template=/TaggedPage/TaggedPage Display.cfm&TPLID=117&ContentID=15272

89 Department of Physical Therapy Graduate Studies in Physical Therapy March 9, 2015 Dear CI, Your dedication to providing quality clinical education to the DPT students of Hardin-Simmons University is certainly appreciated. As you are aware, there are certain responsibilities, rights, and privileges that coincide with your being a Clinical Instructor. As a Clinical Instructor, HSU PT Department expects that you: Discuss your clinical objectives with the student so he/she will know what is expected of him/her from the onset. Will read and sign the acknowledgement of understanding of the Policies & Procedures provided by the PT Department and distributed by your HSU student (Appendix C). Will have one year experience as a PT. Either volunteered to be a CI or was selected by the CCCE due to your competency level. Will provide adequate supervision of the student and appropriate feedback, both positive and constructive. Will complete the necessary paperwork at the completion of the student s rotation in a timely manner. Will demonstrate competency in the clinic as evaluated by the student on the APTA Physical Therapist Student Evaluation: Clinical Experience and Clinical Instruction. For your service as a Clinical Instructor, you are afforded certain rights and privileges by Hardin-Simmons University Department of Physical Therapy as follows: Access to HSU Richardson Library including electronic databases (provide your phone #, name, address, SS #, and address to DCE). Access to PT faculty for consultation. 10% discount at HSU Bookstore (contact DCE). Part II of the CI credentialing course at HSU offered for a nominal fee at which you will receive.8ccu and CI Certification from the Texas Consortium for Physical Therapy Education, Inc. Certificate of Appreciation from HSU. Monthly HSU Lunch & Learn seminars of.1 CCU offered free of charge. Job openings for your facility posted at HSU for our students and distributed via to our graduates. The student and/or DCE may nominate the CI for Outstanding Clinical Instructor award from the Texas Consortium, Inc. if the CI meets certain criteria (e.g. member of APTA, three years experience as a PT and one at that facility, etc.). This is a true honor as a maximum of 10 Clinical Instructors receive this award annually. The Department of Physical Therapy at HSU recognizes clinical instructors as clinical faculty, however, CI s are not considered employees of the University not recognized within the Rank & Tenure structure. Your commitment to our profession and especially to clinical education is sincerely valued. We give our heartfelt thanks for serving as a Clinical Instructor to the students of HSU. Sincerely, Mary Lou Garrett PT, DPT, PCS Director of Clinical Education For Library access, contact Mary Lou at mgarrett@hsutx.edu or Box 16065/Abilene, TX /