Can an unlicensed person perform say 97110 service as long as they're under doctor supervision? I use only PT, ATC, or DC's to perform these codes and I've been told that I don't need such highly qualified therapists to perform therapy. 

 

Depends on the state regulatory boards who set the administrative practice standards, laws, and rules. They determine whether or not the provider can delegate certain services that require clinical skill and licensing to non-licensed individuals. Check with your state board to verify if this is possible and then check with the individual payers with whom you are contracted to verify if they have any set policies on that as well. If the payer states it is inappropriate to delegate these services to unlicensed individuals (even under the provider's supervision) even when the state regulatory board states it's allowed, then do not engage in that activity to avoid any potential allegations of fraud.