BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 721
                                                                  Page  1

          Date of Hearing:   April 21, 2009

                   ASSEMBLY COMMITTEE ON BUSINESS AND PROFESSIONS
                                 Mary Hayashi, Chair
                     AB 721 (Nava) - As Amended:  April 13, 2009
           
          SUBJECT  :   Physical therapists:  direct access to services.

           SUMMARY  :   Allows an individual to initiate physical therapy  
          treatment directly from a licensed physical therapists (PT)  
          without a referral, as specified.  Specifically,  this bill  :  

          1)Permits an individual to initiate physical therapy treatment  
            directly from a licensed PT, provided that the treatment is  
            within the scope of practice of a physical therapist and all  
            the following conditions are met:

             a)   If the PT has reason to believe that the patient has  
               signs or symptoms of a condition that requires treatment  
               beyond the scope of practice of a PT, the PT shall refer  
               the patient to a licensed physician and surgeon, dentist,  
               podiatrist, or chiropractor;

             b)   The PT shall disclose any financial interest he or she  
               has in treating the patient; and,

             c)   With the patient's written authorization, the PT shall  
               notify the patient's physician and surgeon that the PT is  
               treating the patient.

          2)States that this shall not be construed to expand or modify  
            the scope of practice for PTs.

          3)Specifies that it does not require a health care service plan  
            or insurer to provide coverage for direct access to treatment  
            by a PT.

          4)Makes Legislative findings and declarations.

           EXISTING LAW  :

          1)Establishes the Physical Therapy Board of California (Board)  
            within the Department of Consumer Affairs for the purpose of  
            licensing and regulating physical therapists.









                                                                  AB 721
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          2)Defines "physical therapy" as the art and science of physical  
            or corrective rehabilitation or of physical or corrective  
            treatment of any bodily or mental condition of any person by  
            the use of the physical, chemical, and other properties of  
            heat, light, water, electricity, sound, massage, and active,  
            passive, and resistive exercise, and shall include physical  
            therapy evaluation, treatment planning, instruction and  
            consultative services.  

          3)Specifies that physical therapists are explicitly prohibited  
            from diagnosing diseases or other medical conditions. 

           FISCAL EFFECT  :   Unknown

           

          COMMENTS  :   

           Purpose of this bill  .  According to the author's office,  
          "Currently, patients must incur additional co-pays in order to  
          receive referrals for evaluation and treatment from a PT.   
          Additionally, patients often experience delays in treatment when  
          waiting for referrals, which can result in higher costs to  
          consumers and insurance companies, along with decreased  
          functional outcomes.  California's current medical referral  
          system for physical therapy is inefficient, costly, and  
          unnecessary."

           Background  .  Currently, an individual is referred for physical  
          therapy treatment following a diagnosis from a licensed  
          physician and surgeon, dentist, podiatrist, or chiropractor.   
          PTs are statutorily prohibited from determining diagnoses, and  
          this bill emphasizes that it shall not be construed to expand or  
          modify the PT scope of practice. However, this bill authorizes  
          PTs to initiate treatment of an individual without a referral,  
          which presents a logical inconsistency. 

          Although the Business and Professions Code does not explicitly  
          prohibit direct access, a binding May 1965 Attorney General (AG)  
          opinion determined that a physical therapist may only treat a  
          patient's ailment that has been diagnosed by another medical  
          health care professional.  The AG stated:

               We note, preliminarily, that the practice of medicine  
               is composed of at least three consistent part:  








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               diagnosis, prescription, and treatment [citations  
               omitted].  Licensed physical therapists are  
               authorized, by section 2660, to practice on phase of  
               healing art, namely treatment, but are specifically  
               not authorized to diagnose. The third question  
               presented asks in effect, whether it is possible to  
               treat an abnormal condition without a prior  
               determination of the nature and character of the  
               abnormality.  The answer is clearly in the negative.

          This bill would allow a PT to treat a patient without a  
          diagnosis of the problem.  Business & Professions Code 2038  
          defines diagnosis as: 

               ?[an] undertaking by any method, device, or procedure  
               whatsoever, and whether gratuitous or not, to  
               ascertain or establish whether a person is suffering  
               from any physical or mental disorder.  Such terms  
               shall also include the taking of a person's blood  
               pressure and the use of mechanical devices or machines  
               for the purpose of making a diagnosis and representing  
               to such person any conclusion regarding his or her  
               physical or mental condition.  

          It is unclear how a PT would treat an individual without  
          determining the nature of a person's problem.  In addition to a  
          PT's statutory inability to diagnose, PTs are also prohibited by  
          law from using X-rays to determine the underlying cause of pain  
          or discomfort.    

          A review of other state statutes indicates that 16 other states  
          permit unlimited direct access to PTs.  Six states, including  
          California, do not permit any level of direct access, and the  
          remainders of the states have variations of "limited direct  
          access."  These variations include statutory and regulatory  
          directives relating to duration of treatment, PT education  
          levels, and physician contact.    

          The federal Medicare program requires input from a physician for  
          PT treatment.  The Medicare Payment Advisory Commission,  
          concluded as a result of a 2003 study that, "Several compelling  
          reasons argue for retaining Medicare's current requirements that  
          physicians refer beneficiaries to PT services and oversee their  
          care.  These requirements are in place so that beneficiary  
          health care needs are correctly diagnosed, referred for  








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          treatment, and followed up.  Given many beneficiaries' multiple  
          and chronic health problems, the requirements encourage  
          coordination of the medical care beneficiaries receive."

           Arguments in support  .  According to the California Physical  
          Therapy Association, "Physical therapist education and training  
          requirements have changed dramatically in the last 43 years and  
          justifies clarification and recognition by the Legislature that  
          the profession is qualified to treat patients' symptoms without  
          a formal diagnosis of a disease.  The minimum educational  
          standard to become a physical therapist in California today is a  
          Master's Degree, and approximately 90% of physical therapy  
          programs now end in a Doctoral Degree.  In addition, physical  
          therapists must pass a state and national licensing exam and  
          complete continuing education courses.  Thus, physical  
          therapists are very well trained to provide treatment for  
          musculocskeletal conditions and impairments."

           Arguments in opposition  .  The California Medical Association  
          writes, "This bill will unnecessarily expose patients to risk as  
          physical therapists begin treatments without the advantage of  
          proper laboratory or radiological testing, or lack of  
          understanding of an underlying medical condition.  The Medicare  
          Payment Advisory Commission (MedPAC), in its December 2004  
          report, strongly admonished that Congress should not allow  
          Medicare beneficiaries direct access to physical therapy  
          services, citing that the current system does not in any way  
          impair the beneficiaries' access to physical therapy services?. 

          "Physical therapists serve an important role in healthcare, but  
          their training and education does not authorize them to make  
          diagnoses or evaluate the patient's entire medical condition.   
          Physical therapists are trained to treat, not diagnose, and  
          should not be allowed to function as the first point of contact  
          where initial diagnosis is necessary." 

           Previous legislation  .  AB 1444 (Emmerson) of 2008 was a similar  
          bill that died in the Assembly.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Physical Therapy Association
          Congress of California Seniors








                                                                  AB 721
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          State of California, California Senior Legislature
          85 individual consumers of physical therapy services
          80 physical therapy students
          53 physical therapists

           Opposition 
           
          California Orthopaedic Association
          California Chiropractic Association
          California Medical Association
          Medical Board of California 
           
          Analysis Prepared by  :    Sarah Huchel / B. & P. / (916) 319-3301