Am looking for resources in regards to the use of students and billing at an inpatient rehab facility. My understanding and that of some coworkers is that the student is treating and billing under the CIs license where a entry level student would carry the CI's caseload.

My questions: In a inpatient acute rehab setting if the CI carries a caseload as well as the student, billing for 3-4 patients at a time in one sitting would that be considered a group charge? I also understand that group cannot be charged more than 20% of the patient treatment sessions per week according to CMS. With that in mind, isn't it a violation of medicare to essentially use the student(s) as staff members whereby the student carries a caseload as well as the CI? Isn't the job of a CI to provide mentoring and supervision of a student and how can that be effectively done if the CI is busy with a full case load as well as the student?