Comment on DOD-2009-HA-0098-DRAFT-0002

COMMENT I am Director of the Professional Doctorate in Physical Therapy at the University of Southern California. I would like to speak against the provision that an MD and especially a NP or PA are qualified to provide oversight to a Doctor of Physical Therapist. Physical therapist are licensed under their respective states and educational qualifcations are equivalent to a graduate of a professional medicine degree program and exceeds the education of both the NP and PA. NP and PA are health professionals who are qualified to provide referral but not oversight of a physical therapy plan of care. Dr Katherine Sullivan, PhD, PT The section of the Document ID DOD-2009-HA-0098-0001 is: (2) The services of the following individual professional providers of care to be considered for benefits on a fee-for-service basis may be provided only if the beneficiary is referred by a physician, a certified physician assistant or certified nurse practitioner and a physician, a certified physician assistant or certified nurse practitioner must also provide continuing and ongoing oversight and supervision of the program or episode of treatment provided by these individual paramedical providers. (i) Licensed registered physical therapist and occupational therapist. (ii) Licensed registered speech therapists (speech pathologists). * * * * *