Texas - Physical Therapy Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Executive Council of Physical Therapy and Occupational Therapy Examiners (ECPTOTE) licenses physical therapists in Texas, while the Texas Health and Human Services Commission (HHSC) authorizes these services under Medicaid waivers like Home and Community-based Services (HCS) and Community Living Assistance and Support Services (CLASS). Providers must enroll through the Texas Medicaid & Healthcare Partnership (TMHP) Provider Enrollment and Management System (PEMS) to bill for evaluations and treatments addressing mobility, strength, balance, and fall risk.

Approval requires an active ECPTOTE license and, if operating as an agency, a Home and Community Support Services Agency (HCSSA) license from HHSC. Individual therapists must submit ownership disclosures and complete the Provider Applicant Training (PAT) if contracting directly as a waiver program provider.

1. Service Definition and Scope

Physical Therapy in Texas Medicaid HCBS waivers includes the evaluation, examination, and treatment of clients to restore, maintain, or improve physical function. Services address mobility, strength, balance, and fall risk through therapeutic exercise and modalities.

Under waivers like HCS and CLASS, PT must be medically necessary and ordered by a physician. Services cannot duplicate those available through the Medicaid State Plan or Medicare.

• Service Scope: Evaluation and treatment of physical impairments.
• Target Population: Medicaid waiver participants with functional limitations.
• Delivery Setting: Client homes, community settings, or outpatient clinics.
• Exclusions: Services that are purely maintenance without a skilled therapy need.
• Authorization: Requires prior authorization from HHSC or its designee.

2. Regulatory and Oversight Agencies

Multiple state agencies oversee physical therapy providers in Texas. ECPTOTE handles professional licensure, while HHSC manages waiver program rules and agency licensing.

TMHP acts as the claims administrator and manages the provider enrollment portal.

• Executive Council of Physical Therapy and Occupational Therapy Examiners (ECPTOTE): Issues professional PT licenses (https://ptot.texas.gov).
• Texas Health and Human Services Commission (HHSC): Oversees Medicaid waivers and HCSSA licensing (https://www.hhs.texas.gov).
• Texas Medicaid & Healthcare Partnership (TMHP): Manages PEMS and processes claims (https://www.tmhp.com).
• Contract Application and Management for Providers (CAMP): Portal for HHSC waiver contracting (https://camp.hhs.texas.gov).

3. Gatekeeping Prerequisites: Who Can Even Apply

Before applying to Texas Medicaid, physical therapists must hold an active, unencumbered license from ECPTOTE. Agencies employing PTs must hold a Home and Community Support Services Agency (HCSSA) license from HHSC.

Certain provider types, such as Licensed and Certified Home Health Agencies, must obtain Medicare certification as a prerequisite to enrolling in Texas Medicaid.

• Professional Licensure: Active ECPTOTE physical therapist license.
• Agency Licensure: HCSSA license required for home health agencies.
• Medicare Certification: Required for Licensed and Certified Home Health Agencies before Medicaid enrollment.
• Training Prerequisite: Completion of Provider Applicant Training (PAT) for HCS waiver applicants.
• Competency Exam: In-person competency exam required for HCS program provider applicants.

4. Licensure and Certification Requirements

Individual physical therapists must meet ECPTOTE educational and examination standards. Licenses must not expire within 30 days of the Medicaid application date.

Agencies must maintain their HCSSA license and comply with Texas Administrative Code (TAC) Title 26 requirements.

• Education: Graduation from a CAPTE-accredited physical therapy program.
• Examination: Passing score on the National Physical Therapy Examination (NPTE).
• Jurisprudence: Completion of the Texas Jurisprudence Assessment Module (TX JAM).
• License Renewal: ECPTOTE licenses must be renewed biennially.
• Agency Certification: HCSSA providers must maintain current HHSC licensure.

5. Medicaid Provider Enrollment

Providers enroll via the TMHP Provider Enrollment and Management System (PEMS). Applicants must submit ownership disclosures and applicable business formation documents.

Therapists must enroll according to their specific licensure. Auxiliary staff, such as aides or technicians, cannot enroll as therapy providers.

• Enrollment Portal: TMHP PEMS.
• Ownership Disclosure: PIF-2 forms required for individuals with 5% or more ownership.
• Business Documents: Certificate of Formation or Certificate of Authority for corporations.
• NPI Requirement: Providers must submit claims with their own National Provider Identifier.
• License Verification: TMHP verifies ECPTOTE licensure directly during enrollment.

6. Staffing, Training and Background Checks

Medicaid providers must ensure all staff meet state and federal background check requirements. PTs must complete continuing competence activities to maintain their ECPTOTE license.

Waiver program providers must also complete specific HHSC training modules, including abuse, neglect, and exploitation (ANE) reporting.

• Background Checks: Fingerprint-based criminal history checks required for licensure.
• OIG Exclusion: Staff must be screened monthly against state and federal OIG exclusion lists.
• Continuing Competence: PTs must complete 30 Continuing Competence Units (CCUs) every two years.
• ANE Training: Mandatory training on reporting abuse, neglect, and exploitation.
• CPR Certification: Basic Life Support (BLS) certification required for direct care staff.

7. Documentation, Policies and Records

Texas Medicaid requires strict adherence to documentation standards. Each page of the medical record must document the patient's name and Texas Medicaid number.

Providers must maintain copies of actual authorizations from HHSC or TMHP in the clinical record.

• Record Identification: Patient name and Medicaid number on every page.
• Prior Authorization: Maintained in the medical record for required services.
• Clinical Notes: Must support the selection of CPT evaluation and management codes.
• Allergies: Allergies and adverse reactions prominently noted in the record.
• Retention: Records must be kept for a minimum of five years.

8. Billing, Rates and Claims

Claims are submitted to TMHP using standard CPT codes for physical therapy evaluations and modalities. Reimbursement rates are established by HHSC and published on the TMHP fee schedule.

Providers must bill using their enrolled NPI and follow guidelines in the Texas Medicaid Provider Procedures Manual (TMPPM).

• Claims System: TMHP TexMedConnect or EDI.
• Coding: Standard CPT codes for PT evaluation (e.g., 97161-97163) and treatment.
• Fee Schedule: Rates published on the TMHP Static Fee Schedule page.
• Prior Authorization: Required for most PT services beyond initial evaluations.
• Timely Filing: Claims must generally be filed within 95 days of the date of service.

9. Approval Sequence and Timeline

The approval process begins with ECPTOTE licensure, followed by TMHP PEMS enrollment. PEMS applications typically take 30 to 60 days to process if complete.

Waiver contract applications through the CAMP portal are processed year-round but require prior completion of the PAT and competency exams.

• Step 1: Obtain ECPTOTE physical therapy license (4-8 weeks).
• Step 2: Complete PAT and competency exam for waiver contracting.
• Step 3: Submit TMHP PEMS enrollment application (30-60 days).
• Step 4: Submit HHSC contract application via CAMP portal.
• Step 5: Receive approval email and Medicaid provider number.

10. Common Denials and Survey Findings

Enrollment applications are frequently denied for missing ownership disclosures or licenses expiring within 30 days. Claims are often denied for lack of prior authorization.

During HHSC surveys, agencies are commonly cited for incomplete clinical documentation or failure to conduct required background checks.

• Enrollment Denial: License expiring within 30 days of application.
• Enrollment Denial: Incomplete PIF-2 ownership disclosure forms.
• Claim Denial: Missing or expired prior authorization.
• Claim Denial: Services billed exceed authorized units.
• Survey Finding: Failure to document medical necessity in clinical notes.

11. Key Contacts and Resources

Providers should utilize official state resources for the most current rules and manuals. The Texas Medicaid Provider Procedures Manual (TMPPM) is the primary guide for billing and policy.

For enrollment assistance, providers can contact the TMHP Contact Center.

• TMHP Provider Enrollment: https://www.tmhp.com/topics/provider-enrollment
• ECPTOTE Licensing: https://ptot.texas.gov
• HHSC Waiver Contracting: https://camp.hhs.texas.gov
• Texas Medicaid Provider Procedures Manual: https://www.tmhp.com/resources/provider-manuals
• TMHP Contact Center: 1-800-925-9126

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