Rules that stand between a physical therapy business and opening day

What to take away

• Order the compliance work by lead time, not by importance. The items that take months are the ones that set your opening date.
• Each item below has a sign-off: a named person and a piece of evidence. An item without evidence is not done.
• This is a checklist of questions to close, not a statement of what the law requires. The state physical therapy board, each payer and your compliance adviser supply the requirements.
• After opening, the list becomes a monthly cycle. The items do not go away; they renew.

How to use the list

Copy it into a document with three columns added: owner, evidence, date closed. Work from the longest lead time down. When an item is closed, the evidence is filed in the compliance file that the licensing and compliance guide describes.

Months out: the items that set the opening date

• Every clinician's license verified with the state physical therapy board, printed with the date. Evidence: verification printouts.
• Supervision and delegation rules for assistants and aides obtained from the board in its own words. Evidence: the rule text or the board's written answer.
• The board's position on treatment without a referral obtained in writing. Evidence: the board's published rule.
• Entity formed, tax registrations complete, bank account open. Evidence: formation and tax documents.
• Payer credentialing applications submitted with each payer's timeline recorded. Evidence: submission confirmations and a tracking sheet.
• Each payer's authorization and documentation policy read and dated. For Medicare, the CMS therapy services page holds the coding and billing material, and the CMS compliance tips for physical therapists in private practice list what its reviewers find missing. Evidence: a policy summary per payer with the date read.
• Premises: occupancy, fire and any state location registration questions put to the authorities. Evidence: written answers and inspection bookings.
• Accessibility review of the space by a qualified person, with the Justice Department's ADA guide for small businesses as the owner's introduction to what it covers. Evidence: the review and the remediation list.
• Insurance placed with the wording read, following insurance costs and coverage. Evidence: policy documents and the broker's answers.

Weeks out: the operating rules

• Privacy and security risk assessment done with a compliance adviser; vendor agreements signed for the software and any billing service. Evidence: the assessment and the agreements.
• Documentation template built to the standards of the payers you will bill. Evidence: the template and one completed sample note reviewed against the payer's policy.
• Cancellation and no-show policy written, with the words the front desk will use at intake. Evidence: the policy and the intake script.
• Eligibility and authorization check written into the booking procedure so that no visit is booked outside an authorization. Evidence: the procedure.
• Supervision rules written into the schedule template so that an assistant's column cannot run without the supervision the board requires. Evidence: the template.
• Employment: pay, timekeeping, posted notices and written policies confirmed with the state labor department or a payroll provider. Evidence: the policies and the notices.
• Each hire's credentials and references verified before the start date, as the hiring and training guide sets out. Evidence: the verification file per person.
• Marketing claims checked against the board's advertising rules and consumer protection law before any listing goes live; the marketing and growth guide covers what a listing may say. Evidence: the approved listing text.

The week of opening

1. Walk the premises with the inspection reports and the accessibility list in hand and confirm every open item is closed or has a date.
2. Run one fictitious patient through booking, eligibility, intake, consent, treatment note and claim, and fix whatever the run exposed.
3. Confirm every clinician's license and each payer's effective date against the schedule: nobody treats, and nobody is billed, before their date.
4. Brief the front desk on the three scripts: the cancellation policy, the authorization check, and what to say when a patient asks whether they need a referral.
5. File everything. The compliance file should be complete on the day you open, because the first month leaves no time to build it.

After opening: the monthly cycle

• License and certification renewals checked against the calendar.
• Payer re-credentialing dates checked.
• A sample of notes reviewed against the payer's documentation standard.
• A sample of bookings reviewed for visits outside an authorization or outside supervision.
• Any change in services, location, staff or software logged as a trigger to reopen the map.

What this list does not do

It does not tell you which licenses exist; which licenses a physical therapy business needs is the script for finding that out. It does not replace the board, the payer, or the adviser. It makes sure that every question was asked, that the answer was written down, and that someone owns keeping it current.

Common questions

What is the one item most new owners start too late?

Payer credentialing. Its lead time is set by the payer, and a lease signed before that timeline is known puts rent ahead of revenue.

Can the checklist be shorter for a cash-only practice?

The payer items fall away. The board, premises, privacy, employment and insurance items do not.

Who should own the compliance file?

One named person, which in a small practice is usually the owner. Ownership means checking the calendar monthly, not knowing every rule by heart.