Legislative Analysis
Phone: (517) 373-8080
EXPAND SCOPE OF PRACTICE OF PHYSICAL THERAPY
http://www.house.mi.gov/hfa
Senate Bill 668 (S-2) as passed by the Senate Analysis available at
Sponsor: Sen. Kevin Hertel http://www.legislature.mi.gov
House Committee: Health Policy
Senate Committee: Health Policy
Complete to 11-14-24
SUMMARY:
Senate Bill 668 would amend the Public Health Code to allow physical therapists to treat
patients without a referral, with certain conditions and requirements, and to expand their scope
of practice to allow them to determine the cause, likely course, and intervention plan for a
patient’s physical therapy problem as long as they are not making a medical diagnosis outside
of their scope of practice.
Practice of physical therapy
Under both current law and the bill, the practice of physical therapy means evaluating,
educating, consulting with, or treating an individual by employing physical measures (such as
massage, mobilization, heat, cold, air, light, water, electricity, or sound) and using therapeutic
exercises and rehabilitative procedures, with or without assistive devices, to prevent, correct,
or alleviate a physical or mental disability.
Currently, the practice of physical therapy specifically excludes the identification of underlying
medical problems or etiologies, establishment of medical diagnoses, or the prescribing of
treatment. The bill would remove this language, and instead would specifically exclude the
following:
• The practice of medicine.
• The practice of osteopathic medicine and surgery.
• The practice of podiatric medicine and podiatric surgery.
• Medical diagnosis or the diagnosis of a health condition, if the diagnosis falls outside
the scope of practice of physical therapy.
The bill would further provide that the practice of physical therapy specifically includes
examining, evaluating, and testing an individual with a mechanical, physiological, or
developmental impairment, a functional limitation, or a disability or other health and
movement-related condition to determine a cause of the physical therapy problem to be treated
and a prognosis and plan for intervention.
Eliminate current referral requirements
Currently, a physical therapist or supervised physical therapist assistant can treat a patient if
the treatment is prescribed by an advanced practice registered nurse or a health professional
licensed under the parts of the code that deal with licensure in dentistry, medicine, osteopathic
medicine and surgery, or podiatric medicine and surgery. 1 However, a physical therapist or
1
The bill uses the term health care professional for these licensees, as does this summary below. Note that the term
is used in the bill not just for professionals who are referring patients to a physical therapist, but also for professionals
who are allowed to have a patient referral from a physical therapist (or who the physical therapist is required to consult
House Fiscal Agency Page 1 of 3
 assistant can treat a patient without such a referral for 21 days or 10 treatments, whichever is
less, and also can treat (without time or treatment limitations) any patient who is seeking
physical therapy services to prevent injury or promote fitness.
The bill would eliminate all of the provisions described in the above paragraph.
New requirements for patients without a referral
The code now requires a physical therapist treating a patient without referral to consult with an
appropriate health care professional if the patient does not show reasonable response to
treatment in a period consistent with standards of practice as determined by the Michigan Board
of Physical Therapy.
The bill would instead require a physical therapist treating a patient without referral to consult
with one of the following if the patient does not show reasonable response to treatment within
60 days after treatment is initiated or in a time period consistent with generally accepted
standards of practice (whichever period is shorter):
• If the patient identifies a health care professional as their primary health care
professional, that health care professional.
• If the patient does not identify a health care professional as their primary health care
professional, a health care professional the physical therapist considers appropriate.
In addition, if a patient being treated without referral identifies a health care professional as
their primary health care professional, the physical therapist would have to inform the patient's
primary health care professional of the initial evaluation and plan of care for physical therapy
services for the patient within 15 days after initiating treatment.
A physical therapist who is treating a patient without a referral from a health care professional
would have to inform the patient of their potential financial liability for receiving physical
therapy services without the referral.
Consultation requirement
Under the bill, after identifying any of the following, a physical therapist who is treating a
patient would have to consult with the health care professional who referred the patient, the
health care professional the patient identifies as their primary health care professional, or (if
no primary health care professional is identified) the health care professional the physical
therapist considers appropriate:
• A measurable decline in the patient's condition that requires a significant change to the
patient's plan of care.
• An exacerbation or progression of the patient's symptoms despite adherence to the
patient's plan of care.
• A significant complication that was not present when the initial evaluation occurred
and the plan of care was initially drafted for the patient.
The consultation would have to be made as soon as possible, but not later than five days after
the conditions described above are identified.
with, etc.). It is unclear whether as a practical matter a physical therapist would ever need to consult with or refer a
patient to a licensed health professional who is not included in the bill’s definition, or whether the way the term is
defined and used would restrict their ability to do so.
House Fiscal Agency SB 668 (S-2) as passed by the Senate Page 2 of 3
 Other provisions
The code currently states that it does not require new or additional third-party reimbursement
or mandated worker's compensation benefits for physical therapy services and does not
preclude a third party payer from requiring a member or enrollee to fulfill benefit requirements
for physical therapy services, including any of the following services when rendered by an
individual licensed or otherwise authorized under this part:
• Prescription.
• A referral.
• Preapproval.
The bill would add “a medical differential diagnosis to demonstrate medical necessity” to the
list of examples of physical therapy services for purposes of the above provisions.
The bill would take effect 180 days after its enactment.
MCL 333.17801 et seq. and proposed MCL 333.17825a
FISCAL IMPACT:
Senate Bill 668 would not have a fiscal impact on any units of state or local government.
Legislative Analyst: Rick Yuille
Fiscal Analyst: Una Jakupovic
■ This analysis was prepared by nonpartisan House Fiscal Agency staff for use by House members in their
deliberations and does not constitute an official statement of legislative intent.
House Fiscal Agency SB 668 (S-2) as passed by the Senate Page 3 of 3


Statutes affected:
Substitute (S-2): 333.17801, 333.17819
Senate Introduced Bill: 333.17801, 333.17819
As Passed by the Senate: 333.17801, 333.17819