Working in private practice as an OT, PT, or SLP: what Medicare, APTA, and ASHA say

Medicare has its own category for therapists in private practice, defined in the Benefit Policy Manual and in 42 CFR 410.59, 410.60, and 410.62. Those rules cover the practice types, the office space, and supervision, and the manual and the current regulation word supervision differently. APTA’s Private Practice section and ASHA’s private-practice page list what owners should look into. This page quotes them; it is not advice on starting, licensing, or running a business.

Quoted from official pages checked November 10, 2026. Confirm current requirements, fees, and dates on those sites. This page is not legal advice and does not guarantee eligibility, certification, or licensure.

Sources read on November 10, 2026: the Medicare Benefit Policy Manual, Chapter 15, section 230.4 (Rev. 179, issued January 14, 2014); 42 CFR 410.59 (occupational therapy), 410.60 (physical therapy), and 410.62 (speech-language pathology) on eCFR, up to date as of November 6, 2026; APTA’s Private Practice page and APTA Private Practice’s Opening a Private Practice page; and ASHA’s Private Practice in Speech-Language Pathology page. AOTA’s private-practice address returned an empty response in a plain read, so no AOTA material is quoted.

Medicare’s therapist in private practice

Section 230.4 states: “TPP refers to therapists in private practice (qualified physical therapists, occupational therapists and speech-language pathologists).” It states: “In order to qualify to bill Medicare directly as a therapist, each individual must be enrolled as a private practitioner and employed in one of the following practice types: an unincorporated solo practice, unincorporated partnership, unincorporated group practice, physician/NPP group or groups that are not professional corporations, if allowed by state and local law.” It also states: “Private practice does not include individuals when they are working as employees of an institutional provider.”

The regulations use shorter wording. For each profession, they require the therapist to “Engage in the private practice” of that therapy “on a regular basis as an individual, in one of the following practice types: a solo practice, partnership, or group practice; or as an employee of one of these.” The OT and PT sections both say private practice office space “must be owned, leased, or rented by the practice and used for the exclusive purpose of operating the practice.” The manual has the same space requirement. The National Provider Identifier is covered on the NPI page.

Supervision: the manual and the regulation side by side

Section 230.4 B, dated 2014, states: “The therapy services must be provided either by or under the direct supervision of the TPP.” It states: “Direct supervision requires that the supervising private practice therapist be present in the office suite at the time the service is performed. These direct supervision requirements apply only in the private practice setting and only for therapists and their assistants.”

The current eCFR text of 42 CFR 410.60 states: “Physical therapy services may be performed by a physical therapist assistant under the general supervision of the physical therapist in private practice; services performed by an unenrolled physical therapist must be under the direct supervision of the physical therapist.” 42 CFR 410.59 states: “Occupational therapy services may be performed by an occupational therapy assistant under the general supervision of the occupational therapist in private practice; services performed by an unenrolled occupational therapist must be under the direct supervision of the occupational therapist.”

The manual and the regulation are quoted as each reads on November 10, 2026 and are not reconciled here. State law can be stricter. See supervision rules and ask your Medicare Administrative Contractor.

Physical therapists: APTA

APTA’s Private Practice page states: “If you own or work in a PT–owned private practice, we have resources to support you.” It also states: “The APTA Private Practice Section is specifically dedicated to those interested in business and management, whether you own a practice or are considering starting one.” APTA Private Practice’s page states: “The mission of APTA Private Practice is to champion the success of the physical therapist in business.” Its start-up steps (business plan, location, financing, staffing, marketing) are on that page and are not summarized here.

Speech-language pathologists: ASHA

ASHA’s page states: “Whether you see a few clients privately or are looking to build a full-time business, the following resources can help you establish a private practice.” The areas it lists include “learning about local and state regulations”, “obtaining liability insurance”, “considering documentation”, and “learning about billing and reimbursement”.

On orders, it states: “SLPs are autonomous professionals. However, a physician’s order or prescription may be required for reimbursement from third-party payers such as Medicare, Medicaid, or private insurance companies.” On estimates: “If you serve individual clients, you’ll need to provide them a good-faith estimate before starting services or at any time during treatment.” See good faith estimates. On records, it states: “No matter how you maintain your records, it’s important to understand your responsibilities related to complying with HIPAA—the Health Insurance Portability and Accountability Act”. See HIPAA for OT, PT, and SLP.

Occupational therapists

Medicare’s OT private-practice rules are quoted above. AOTA’s private-practice page returned no readable content on November 10, 2026, so nothing from AOTA is quoted.

Pay and settings

This page copies no wages or employer shares. BLS figures for “Offices of physical, occupational and speech therapists, and audiologists” are on outpatient clinics and private practice, and national pay is on pay and outlook.

What this page does not do

It gives no fee schedules, payment rates, or productivity targets, and it is not advice on business formation, insurance credentialing, or taxes. It is not legal, billing, tax, or compliance advice. Confirm current rules with the agency that publishes them, your employer, and your state board.