August 10, 2026
Aetna has made significant changes to its policies governing physical therapy and occupational therapy that reduce traditional physician-order and plan-of-care signature requirements.
For outpatient rehabilitation providers in Florida, these changes are particularly important because Florida law already permits substantial direct access to both physical therapy and occupational therapy.
The result is an important distinction between three separate issues that providers often mistakenly treat as the same thing: • Whether Florida law permits a therapist to evaluate and treat a patient without a referral; • Whether Aetna requires a physician order or physician signature as a condition of medical necessity; and • Whether a particular Aetna benefit plan requires a referral, authorization, or precertification.
Those questions must be analyzed separately.
What Is Direct Access?
Direct access generally means that a patient may seek evaluation and treatment from a licensed physical therapist or occupational therapist without first obtaining a prescription or referral from a physician or another health care practitioner.
However, direct access is governed primarily by state scope-of-practice law.
Insurance companies can also establish contractual requirements affecting coverage and payment. Therefore, a therapist may legally be permitted to treat a patient under state law while a particular insurance plan may separately require authorization, precertification, or another administrative step before it will pay for the services.
Aetna itself emphasizes that its Clinical Policy Bulletins are used to administer benefits and that the terms of the individual member’s benefit plan ultimately control coverage.
For Florida providers, it is therefore important to understand both Florida direct-access law and Aetna’s current policies.
Florida Direct Access for Physical Therapy
Florida expressly permits physical therapists to evaluate and begin treating patients without first obtaining a physician referral.
The governing law is Florida Statutes § 486.021(11)(a).
Under the statute, a Florida-licensed physical therapist may develop and implement his or her own plan of treatment for a patient. A treatment plan may alternatively be supplied by a practitioner of record or an advanced practice registered nurse.
This means that a Florida physical therapist does not generally need a physician prescription or referral before beginning physical therapy treatment.
Florida law nevertheless places important limits on that direct access.
The 30-Day Rule for Florida Physical Therapy
If the patient’s condition has not previously been assessed by a practitioner of record, and physical therapy treatment is required beyond 30 days, Florida law requires the physical therapist to have a practitioner of record review and sign the plan of treatment.
This is an important distinction.
Florida does not impose a blanket requirement that a physician sign every physical therapy plan of care.
Instead:
Days 1–30: A Florida physical therapist may generally evaluate the patient, establish a plan of treatment, and provide physical therapy without first obtaining a physician referral or signature.
Beyond 30 days: If the condition was not previously assessed by a practitioner of record and PT treatment remains necessary, the practitioner of record must review and sign the treatment plan.
Florida law defines an eligible practitioner of record for this purpose as an actively practicing health care practitioner licensed under specified chapters governing physicians, osteopathic physicians, chiropractors, podiatrists, and dentists.
When the 30-Day Physician Review Requirement Does Not Apply
Florida law also provides an exception.
The practitioner-review-and-signature requirement does not apply where the patient has already been physically examined by a physician licensed in another state, that physician has diagnosed the patient with a condition requiring physical therapy, and the physical therapist is treating that diagnosed condition.
PTs Must Refer When the Condition Is Outside Their Scope
Direct access does not mean unlimited independent medical management.
Florida law requires the physical therapist to refer the patient to or consult with a practitioner of record when the patient’s condition is outside the scope of physical therapy.
That clinical obligation exists regardless of whether an insurance carrier requires a referral.
The Florida PT direct-access rule can therefore be summarized as follows:
Florida PT Direct Access
Referral required before initial evaluation? Generally, no.
Physician order required to initiate PT? Generally, no.
Can the PT create the treatment plan? Yes.
Can treatment begin immediately? Yes, when clinically appropriate and within the PT’s scope.
When is practitioner review required? If treatment continues beyond 30 days for a condition that was not previously assessed by a practitioner of record.
Must the PT refer for conditions outside the PT scope? Yes.
Florida Direct Access for Occupational Therapy
Florida’s occupational therapy law is structured differently.
The Florida Occupational Therapy Practice Act is contained in Chapter 468, Part III, Florida Statutes.
Florida law broadly defines occupational therapy to include the assessment, treatment, education, and consultation services provided by occupational therapists for individuals whose ability to participate safely and independently in occupations has been impaired or is at risk of impairment.
The Florida statute authorizes licensed occupational therapists to perform assessment and treatment within their statutory scope of practice.
Importantly, the Florida Occupational Therapy Practice Act does not contain the same 30-day practitioner-review requirement that appears in Florida’s Physical Therapy Practice Act.
In other words, Florida’s OT statute does not establish a general rule requiring an occupational therapist to obtain a physician referral before evaluating or treating a patient.
Nor does the OT statute impose the PT statute’s requirement that a physician or other practitioner review and sign the plan after 30 days.
The Occupational Therapist Controls the OT Plan of Treatment
Florida law defines OT supervision in a way that further recognizes the occupational therapist’s responsibility for treatment planning.
When an occupational therapy assistant is involved, the supervising occupational therapist provides the initial direction in developing the plan of treatment and periodically inspects its implementation. The treatment plan may not be altered by the supervised individual without consultation with and approval from the occupational therapist.
This is consistent with occupational therapy being a separately licensed health profession with its own statutory scope of practice.
The Florida OT rules can therefore generally be summarized as follows:
Florida OT Direct Access
Physician referral required under the Florida OT Practice Act before evaluation? No general referral requirement appears in the statute.
Physician order required to begin occupational therapy under the state practice act? No general physician-order requirement appears in the statute.
Can the occupational therapist perform an assessment? Yes, within the occupational therapist’s licensed scope of practice.
Can the occupational therapist establish the treatment plan? Yes. Florida’s statutory structure places responsibility for the OT treatment plan with the occupational therapist.
Is there a 30-day physician-signature rule like physical therapy? No comparable 30-day requirement appears in Florida’s occupational therapy statute.
That distinction between PT and OT is particularly important when evaluating Aetna’s recent policy changes.
Aetna’s Physical Therapy Direct-Access Change
Aetna revised its physical therapy requirements in 2025.
Effective June 17, 2025, Aetna removed requirements associated with a physician order and physician involvement in the physical therapy plan of care.
The current Aetna Physical Therapy Clinical Policy Bulletin should therefore be read together with applicable state law and the member’s particular benefit plan.
For a Florida patient, this creates an important framework.
Aetna may no longer impose its previous physician-order requirement as part of the clinical policy, but the Florida statutory 30-day rule still applies independently.
Therefore, an Aetna policy change cannot eliminate the Florida requirement that, where applicable, a practitioner of record review and sign the treatment plan when direct-access treatment extends beyond the statutory period.
Florida PT + Aetna
In practical terms:
Initial PT evaluation: No physician referral is generally required by Florida’s PT practice act.
Beginning treatment: The physical therapist may develop and implement the treatment plan.
Aetna physician order: Aetna eliminated its physician-order requirement.
Aetna physician plan-of-care approval: Aetna removed its prior physician plan-of-care approval requirement.
Florida 30-day rule: Still applies. Aetna cannot eliminate a requirement imposed by state scope-of-practice law.
Plan-specific authorization or referral: Must still be verified because the member’s individual benefit plan may contain separate requirements.
Aetna’s New Occupational Therapy Policy Change
Aetna has now moved occupational therapy in substantially the same direction.
Effective May 19, 2026, Aetna revised its Occupational Therapy Clinical Policy Bulletin to remove two significant requirements:
1. The requirement for a physician or other licensed health care practitioner order for occupational therapy; and 2. The documentation requirement for the member’s attending physician to sign the occupational therapy plan of care.
This is particularly important in Florida because Florida’s OT statute itself does not impose the same 30-day physician-signature requirement applicable to physical therapists.
Aetna’s current occupational therapy policy also recognizes the professional concept of independent occupational therapy practice.
In the background section of Clinical Policy Bulletin 0250, Aetna discusses the American Occupational Therapy Association’s Model Occupational Therapy Practice Act and specifically acknowledges the position that an occupational therapist may evaluate, initiate, and provide occupational therapy treatment without a referral from another health service provider.
Aetna nevertheless recognizes that federal law, state law, payer rules, and other regulatory requirements continue to apply.
Aetna’s OT Policy Still Contains Conflicting Language
There is an important issue providers should know about.
Despite Aetna’s May 19, 2026 change eliminating the physician-order and attending-physician-signature requirements, the currently published version of Clinical Policy Bulletin 0250 still contains language in its Medical Necessity section stating that occupational therapy must be provided under an ongoing written plan of care reviewed with and approved by the treating physician in accordance with applicable state laws and regulations.
The current online policy also still contains language near the beginning of its Medical Necessity criteria referring to short-term OT being prescribed by a physician.
At the same time, Aetna’s background section expressly discusses independent occupational therapy practice and treatment without referral.
These provisions create an apparent internal inconsistency.
Providers should therefore distinguish between what Aetna expressly changed in its revision history and language that remains elsewhere in the Clinical Policy Bulletin.
Until Aetna completely reconciles those sections, providers should retain documentation of the May 19, 2026 revision and verify disputed requirements directly when necessary.
Physician Order, Referral, Authorization and Plan-of-Care Signature Are Different Requirements
One of the most important compliance lessons from these changes is that the following terms should not be used interchangeably.
Physician Order
A formal instruction from a physician or other authorized practitioner for therapy to be performed.
Referral
A requirement that the patient be directed to the therapist by a physician, PCP, or another authorized health care practitioner.
Plan-of-Care Signature
A requirement that another practitioner review, approve, certify, or sign the therapist’s treatment plan.
Prior Authorization or Precertification
Approval from the insurance carrier before certain services or quantities of services will be covered.
Direct Access
The legal ability of a patient to seek evaluation or treatment directly from a therapist without first obtaining a physician referral.
Aetna may eliminate its physician-order requirement without eliminating every possible plan-specific referral or prior-authorization requirement.
Similarly, Florida law may permit direct access while a patient’s insurance contract separately imposes administrative conditions for reimbursement.
Florida PT and OT Direct Access Compared
For outpatient rehabilitation providers, the most important distinction is this:
Physical Therapy in Florida
Florida expressly allows a physical therapist to develop and begin a treatment plan without first obtaining a physician referral.
However, if the patient’s condition has not previously been assessed by a practitioner of record and treatment is required beyond 30 days, the practitioner of record must review and sign the plan.
Occupational Therapy in Florida
Florida’s Occupational Therapy Practice Act does not contain the same 30-day practitioner-review requirement and does not establish a general physician-referral prerequisite for evaluation and treatment within the occupational therapist’s lawful scope of practice.
This means that Florida’s direct-access rules are actually different for PT and OT, even though both professions permit significant independent access to care.
What Should an Aetna Provider Do Before Treating a Direct-Access Patient?
A provider should verify four separate layers before assuming that no further administrative requirement applies.
First: State scope-of-practice law
Confirm that the therapist may legally evaluate and treat without referral and whether any duration limitations apply.
For Florida PT, pay particular attention to the 30-day practitioner-review rule.
Second: The patient’s specific Aetna benefit plan
Aetna states that its Clinical Policy Bulletins do not guarantee coverage and that where the terms of the benefit plan differ from a Clinical Policy Bulletin, the benefit plan governs, subject to applicable legal requirements.
Third: Referral requirements
Do not assume that elimination of a physician order automatically eliminates every referral requirement associated with a particular product or benefit design.
Fourth: Authorization or precertification
Direct access and authorization are independent concepts. A patient may legally access therapy without a referral but still require payer authorization for continued treatment or reimbursement.
Aetna maintains separate precertification requirements and tools for determining whether particular services require prior approval.
Why These Aetna Changes Matter
The practical impact of these policy changes is significant.
Requiring a patient to visit a physician simply to obtain a therapy prescription can delay treatment, increase administrative cost, and create unnecessary barriers between the patient and a licensed rehabilitation professional.
Florida law already recognizes physical therapists and occupational therapists as licensed professionals capable of independently assessing patients and developing treatment plans within their respective scopes of practice.
Aetna’s elimination of the physician-order requirement moves its clinical policies closer to that modern direct-access framework.
For occupational therapy in particular, the May 19, 2026 policy revision is substantial because Aetna expressly eliminated both the health care practitioner order requirement and the attending-physician plan-of-care signature requirement.
The Bottom Line
For Florida providers, the current landscape can be summarized simply.
Physical Therapy
Florida permits direct access.
A physical therapist may evaluate the patient, develop the treatment plan, and begin treatment without first obtaining a physician referral.
However, if treatment extends beyond 30 days for a condition that was not previously assessed by a practitioner of record, Florida law requires the practitioner of record to review and sign the treatment plan.
Aetna’s removal of its physician-order and physician-approval requirements does not eliminate this Florida statutory obligation.
Occupational Therapy
Florida’s Occupational Therapy Practice Act does not contain an equivalent 30-day physician-review rule or a general physician-referral prerequisite for occupational therapy performed within the therapist’s lawful scope.
Effective May 19, 2026, Aetna also removed its physician or licensed health care practitioner order requirement and its attending-physician plan-of-care signature documentation requirement.
Aetna’s own OT policy further acknowledges the professional standard permitting occupational therapists to evaluate, initiate, and provide treatment without referral from another health service provider, subject to governing law and payer requirements.
The major unresolved issue is that Aetna’s currently published OT policy continues to contain older language referring to physician prescribing and physician review or approval of the plan of care.
Providers should therefore preserve copies of Aetna’s applicable revision history and policies and should separately confirm:
State law → Benefit eligibility → Referral → Authorization → Medical necessity
Direct access does not eliminate those other coverage considerations.
But from a Florida scope-of-practice perspective, and in light of Aetna’s recent policy revisions, there has been a clear movement toward allowing patients to obtain physical and occupational therapy services without unnecessary physician-order barriers.
⸻
Important Compliance Disclaimer
This article is intended for educational and informational purposes and is not legal advice, billing advice, or a guarantee of insurance reimbursement. Direct-access requirements vary by state, health plan, employer group, product, and benefit design. Medicare, Medicaid, workers’ compensation, personal injury arrangements, federal programs, facility regulations, and other payer-specific requirements may impose additional conditions. Providers should verify current Florida law, the patient’s individual Aetna benefit plan, eligibility, authorization requirements, referral requirements, and applicable clinical policies before rendering or billing for services.
Ready to start feeling better?
Physical Therapy NOW™ has 40+ Florida locations with same-week appointments. Most insurance, auto accident (PIP), workers' compensation and Medicare accepted.
