Performing an FCE independently? Not allowed for PTAs.

Performing an FCE independently? Not allowed for PTAs.

But they can assist—in certain States.`

The bottom line in the U.S. is that Functional Capacity Evaluations are considered evaluations and must be performed by those whose scope-of-practice includes evaluation – i.e. licensed PTs, OTs, or similar. PTAs do not have evaluative scope in any state, and exercise therapists (absent a license) cannot independently take on this role in any official capacity. PTA involvement in FCE is limited to assisting their supervising PT, and any exercise specialist might contribute data or consultation, but the final FCE determinations and report need to come from a licensed professional for it to carry weight.

In summary, for all U.S. states:

  • Physician or Insurance-Referred FCEs: must be performed by licensed practitioners (PT, OT, or in some cases a physician or chiropractor, depending on jurisdiction). PTAs cannot be the evaluator of record. Exercise specialists without licenses are not recognized providers for these referrals.

  • Employer-Requested FCEs: if purely for occupational screening (and not part of a medical claim), could be done by non-licensed testers, but most employers utilize medical professionals or require medical clearance. A PTA might administer a company’s functional test if supervised by a PT, but the PTA alone doing it would be uncommon and potentially viewed as unlicensed practice if any medical judgment is involved.

  • Workers’ Compensation FCEs: universally require a licensed provider’s report. Many states have guidelines or fee schedules for FCE (e.g. Texas) that, while not always explicitly naming the credential, assume the evaluator is a qualified healthcare provider. Thus, PTAs and unregulated exercise personnel are not accepted for independent FCEs in the workers’ comp system.

Functional Capacity Evaluations (FCEs) are assessments of an individual’s physical (and sometimes cognitive) abilities relative to work or daily activity demands. While an FCE itself is generally not a separately regulated procedure, who may perform an FCE is governed by professional scope-of-practice rules and referral source requirements. Below is a detailed overview for various regions in the United States (each state), – focusing on whether Physical Therapist Assistants (PTAs) or “exercise therapists” (e.g. kinesiologists, exercise physiologists) can conduct FCEs. Each section also notes differences based on the referring entity (physician, employer, insurer, etc.), with citations to official regulations or guidelines wherever available.

United States (by State)

In the U.S., FCEs are typically performed by licensed physical or occupational therapists. PTAs are uniformly not permitted to perform initial evaluations or independent assessments in all states, which by extension includes FCEs, since those are considered evaluative procedures. The ability of an “exercise therapist” (e.g. exercise physiologist or other unlicensed evaluator) to perform an FCE is not explicitly regulated in most states; however, in practice most referral sources (physicians, insurers, employers) require a licensed health professional to conduct and sign off on FCE results.

Summary (U.S.): Across all 50 states, PTAs are not allowed to perform FCEs independently because FCEs involve evaluation and judgment reserved to the physical therapist. Many state boards (e.g. Ohio, North Carolina, West Virginia) have explicitly stated that FCEs are beyond PTA scope and must be done by a PT. PTAs can play a support role in administering standardized tests during an FCE only under a PT’s close supervision and only for non-interpretive tasks.

“Exercise therapists” (such as exercise physiologists or kinesiologists) are generally unregulated in the U.S., with the notable exception of Louisiana’s licensed Clinical Exercise Physiologists (who have a very specific practice scope). Because FCEs are not a legally protected act by themselves, in theory anyone could administer one if qualified – but referral sources and payers impose practical limits. Physicians, employers, and insurers will almost always require that the FCE be performed by a licensed health care professional with appropriate training, typically a PT or OT. In workers’ compensation cases, for example, FCEs are commonly performed by physical or occupational therapists who often obtain additional FCE certification. If an FCE is done outside of a medical context (e.g. a pre-employment functional screen arranged by an employer), it might be conducted by a non-PT (like a certified athletic trainer or exercise physiologist) – but even then, many employers prefer or require a PT’s sign-off to ensure the evaluation adheres to accepted standards and to reduce liability.

Below is a state-by-state breakdown:

Alabama

  • PTAs: Alabama’s physical therapy practice rules reserve patient evaluations to the PT. A PTA may not perform an FCE independently, as it is an evaluative service requiring a PT’s interpretation and plan development. The PTA can assist with data collection during an FCE, but the PT must examine the patient and interpret the findings.

  • Exercise Therapists: Alabama does not license exercise physiologists or similar “exercise therapists.” An employer could theoretically engage a non-PT to do a work capacity test, but such an evaluator would not be recognized under any Alabama PT/OT licensing provisions. In a medical or insurance context, an FCE is expected to be done by a licensed PT or OT, not an unlicensed exercise specialist.

  • Referral Context: Physician referrals for FCE (e.g. to assess an injured worker’s capacity) are directed to PTs or OTs. If an employer requests a pre-employment or fitness-for-duty FCE, it may be performed by a PT or other qualified evaluator; a PTA alone would not meet the required qualifications. Workers’ compensation carriers in Alabama typically require FCEs by credentialed providers (PT, OT, or physician), aligning with the general principle that evaluative reports come from licensed professionals.

Alaska

  • PTAs: Alaska’s statutes stipulate that PTAs work under PT supervision and may not perform initial patient evaluations or re-evaluations. Thus, a PTA cannot independently perform an FCE, since it falls under the evaluation category. Any FCE in a clinical context must be led and concluded by a licensed PT, with the PTA only assisting in permissible tasks (e.g. monitoring effort, recording measurements) as directed.

  • Exercise Therapists: Alaska does not regulate exercise physiologists or similar roles. An FCE-style “work capacity” test performed outside of healthcare (e.g. by a fitness professional for an employer) is not explicitly illegal, but for medical or legal purposes (such as workers’ comp claims) the evaluator would need to be a licensed health provider. In practice, FCE referrals in Alaska go to PT/OT clinics or multidisciplinary rehab centers.

  • Referral Context: For physician referrals or insurer requests (like an independent FCE for disability determination), a licensed PT or OT performs the evaluation. Employers who require post-offer or return-to-work FCEs typically contract those out to therapy providers; they would not use a PTA unsupervised, and would favor a licensed practitioner to ensure results are credible and defensible.

Arizona

  • PTAs: Arizona’s physical therapy regulations assign evaluation, assessment, and plan-of-care design exclusively to the physical therapist. A PTA cannot perform a functional capacity evaluation independently. The supervising PT must conduct the FCE’s critical components: examining the patient, determining maximum functional ability, and making return-to-work recommendations. The PTA’s role is limited to assisting with portions of the test (as directed) and not any interpretive or decision-making aspects.

  • Exercise Therapists: Arizona does not license exercise therapists or kinesiologists. Any FCE done for insurance or physician purposes must be by a licensed PT/OT. For an employer-initiated FCE, if it’s purely for hiring or fitness screening (and not billed as healthcare), an exercise specialist could administer tests; however, many employers in Arizona still use occupational health clinics (with PTs or OTs) for formal FCEs to ensure standardization and legal defensibility.

  • Referral Context: Physician or insurer referrals for FCE will end up with a PT or OT evaluator (PTAs can participate only under direct PT supervision, not as the primary examiner). Workers’ compensation in Arizona follows general norms that FCEs are valid when performed by qualified professionals (often PTs/OTs with FCE training). Employer direct requests might have more flexibility, but if a PTA were to perform a standalone “work test” without a PT, it could be seen as practicing physical therapy without a license if it involves any clinical judgments.

Arkansas

  • PTAs: In Arkansas, a PTA may not conduct initial evaluations or interpret evaluation findings under the Arkansas Physical Therapy Practice Act. Accordingly, a PTA cannot perform an FCE except under the direction and immediate supervision of a PT. All evaluative elements – such as determining the patient’s functional limitations and safe working abilities – must be done by the PT. The PTA can assist (e.g. set up tests, record measurements) but cannot author or sign the FCE report or make return-to-work conclusions.

  • Exercise Therapists: Arkansas does not have state licensure for exercise physiologists or other exercise therapists. FCEs intended for workers’ comp, disability, or clinical use are expected to be performed by licensed providers (PT, OT, or sometimes physicians). An “exercise therapist” without a license would not be recognized by state regulators or insurers as a qualified FCE examiner.

  • Referral Context: Physician-referred FCEs go to PTs/OTs. The Arkansas workers’ compensation commission and insurers typically only reimburse FCEs done by credentialed professionals. If an employer arranges an FCE (e.g. fitness-for-duty exam), they commonly use occupational health PTs/OTs. A PTA alone would not meet the requirement, regardless of referral source, since any patient-specific functional assessment falls under practicing physical therapy (which the PTA cannot do independently).

California

  • PTAs: California explicitly prohibits PTAs from performing any physical therapy evaluation, which includes FCEs conducted as part of patient care. The Physical Therapy Board of California has clarified that a PTA cannot perform a “physical therapy FCE” or functional capacity evaluation on a patient. However, California draws a distinction for non-clinical contexts: a PTA may participate in a “pre-employment FCE” – essentially a post-offer physical ability test for job candidates – because that is not considered the practice of physical therapy. Even then, the PTA would be functioning as a tester, not providing a medical opinion. Any FCE that is part of treatment or disability evaluation must be done by the PT (the PTA can only assist with delegated tasks and data collection, not the evaluation or report conclusions).

  • Exercise Therapists: California does not license exercise physiologists, but it does have a large community of kinesiologists and certified ergonomists. In California’s legal framework, performing an FCE per se isn’t restricted to certain licenses, yet referral sources “self-regulate” by requiring proper qualifications. Insurers and employers in California typically require FCEs to be done by licensed professionals (PTs, OTs, or physicians). Exercise specialists (e.g. certified strength coaches or kinesiologists) might conduct workplace functional testing for an employer, but their reports would likely not satisfy workers’ compensation or healthcare requirements unless overseen or co-signed by a licensed provider. Notably, California’s workers’ comp uses the term “Functional Capacity Assessment” in some guidelines, which are usually performed by PTs or OTs with specialized training.

  • Referral Context: For a physician referral or insurer request, a California FCE must be performed by a qualified licensed practitioner – usually a PT or OT with FCE training. The PTA cannot be the examiner of record. If an employer directly requests an FCE (such as a post-offer employment test), California allows more leeway: the employer might have the test done by an occupational health provider or trained evaluator (not necessarily a PT), and a PTA could conduct such a test if it’s clearly not under the banner of providing physical therapy. (In practice, many occupational testing services in CA employ athletic trainers or exercise physiologists for pre-employment screens, but these are non-clinical assessments.) In summary, within clinical and insurance contexts, the PT or OT must perform (and sign off on) the FCE, whereas purely administrative/workplace FCE requests can be handled by other personnel – though even then, many employers prefer a PT/OT for consistency and liability reasons.

Colorado

  • PTAs: Colorado regulations mirror the national standards: a PTA cannot perform initial evaluations or determine discharge readiness. An FCE is considered a specialized evaluation of function; therefore, a PTA is not authorized to independently carry out an FCE in Colorado. The supervising PT must perform the assessment of the patient’s abilities and limitations, and only the PT can interpret the results and compile the FCE report. The Colorado Physical Therapy Board expects that all evaluative procedures are done by the PT, with PTAs only implementing treatment or assisting as directed in gathering objective data.

  • Exercise Therapists: Colorado does not license exercise therapists (no state license for exercise physiologist or kinesiologist). In practice, FCEs are done by PTs, OTs, or physicians in occupational medicine. An exercise professional without a license might be involved in work conditioning programs, but for the formal FCE evaluation of record (especially if for workers’ comp or legal purposes), a licensed provider is needed. Colorado employers and insurers adhere to this – for example, workers’ compensation FCEs are typically performed by certified FCE evaluators who are PTs or OTs.

  • Referral Context: Physician referrals for FCE in Colorado (such as after an injury) would be sent to a PT or OT department; a PTA would not receive such a referral independently. Employer-requested FCEs (pre-hire or return-to-work assessments) are often done by occupational health clinics; while these might involve non-PT personnel for test administration, a Colorado-licensed health professional generally oversees the process and signs the report. Insurers (workers’ comp or disability) commonly require that the FCE report come from a qualified health practitioner, so using a PTA alone or an unlicensed exercise therapist would not meet those requirements.

Connecticut

  • PTAs: Connecticut law requires that physical therapy evaluations and any determination of functional capacity be made by the licensed physical therapist. A PTA is not permitted to conduct a patient evaluation or assessment – which includes FCEs. If an FCE is needed, the PT must examine the individual, supervise any test activities, and draw conclusions. A PTA may, under PT supervision, help administer certain tests in the FCE (for instance, setting up lifting tasks or recording heart rate), but cannot independently perform the evaluation or modify it based on patient response. This aligns with the general rule across states and with Medicare policies (PTAs “are not permitted to perform evaluations or assessment procedures” on their own).

  • Exercise Therapists: Connecticut does not have licensure for exercise physiologists or similar roles. FCE services in the state are typically offered by rehab hospitals, therapy clinics, or independent occupational health evaluators – all of which use licensed professionals (PTs or OTs) to perform the assessment. A personal trainer or exercise specialist without a license would not be recognized by insurers or the Connecticut Workers’ Compensation Commission as an authorized FCE provider. There may be ergonomists or vocational evaluators involved in some capacity evaluations, but again, their work is usually adjunct to the medical FCE done by a therapist.

  • Referral Context: In Connecticut’s workers’ compensation system, FCEs are often requested by adjusters or physicians to clarify an injured worker’s abilities. These FCEs must be done by credentialed practitioners (commonly PTs or OTs certified in FCE). A physician referral for an FCE will be executed by a PT/OT – the PTA cannot accept such a referral independently. For employers seeking fitness-for-duty exams, they will likewise use occupational health services. Overall, the referral source (doctor, employer, or insurer) will expect a licensed PT or OT to conduct the FCE; any assistance by a PTA must be under the direct auspices of the PT in charge, and exercise-only professionals would not be considered qualified to issue the final report.

Delaware

  • PTAs: Delaware’s Board of Physical Therapy defines the PTA’s role as assisting in treatment after the evaluation and plan of care are established by the PT. PTAs cannot initiate or perform patient evaluations. Therefore, a PTA cannot perform an FCE in Delaware independently. The PT must perform the FCE, including any pre-test medical screening, the evaluation of musculoskeletal and functional performance, and the analysis of results. A PTA may help with administering certain test components if the PT is present or directing it, but may not make judgments about maximal effort or safe job capabilities – those are the PT’s responsibility.

  • Exercise Therapists: Delaware has no state licensure for exercise therapists. FCEs for workers’ comp or disability cases are done by licensed therapists (PT/OT). If an employer were to conduct an in-house ability test (for example, for a job requiring lifting), they might have a non-licensed athletic trainer or exercise specialist facilitate it, but any such testing would be kept separate from “physical therapy.” It would also lack legal standing compared to an FCE by a licensed provider. Insurers in Delaware would not accept an FCE report from an unlicensed individual as evidence of disability or work capacity.

  • Referral Context: Physicians in Delaware referring a patient for FCE will refer to a PT or OT. The Delaware workers’ compensation regulations don’t explicitly list who can do FCEs, but in practice only medical or allied health professionals’ reports are considered. A PTA cannot be a referral endpoint; they can only be involved under a PT’s supervision. For employer referrals (e.g., a police department wanting to ensure an officer’s fitness for duty), they typically contract out to therapy clinics or occupational health providers rather than use uncredentialed staff, to ensure the evaluation is comprehensive and defensible.

Florida

  • PTAs: Florida law is clear that only the physical therapist can perform examinations, evaluations, and assessments of patients (the PTA’s scope is limited to interventions in the established plan of care). Thus, in Florida a PTA cannot independently perform a Functional Capacity Evaluation. The FCE – considered a complex assessment of an individual’s functional abilities – must be conducted by a licensed PT or another qualified evaluator (such as an OT) in Florida. The PT can delegate certain tasks during the FCE to the PTA (for instance, demonstrating tasks to the client or gathering objective measurements), but the PTA cannot interpret results or make the final judgments about the client’s functional capacity.

  • Exercise Therapists: Florida does not license exercise physiologists or generic “exercise therapists.” FCEs in Florida are often offered by physical therapy clinics or rehabilitation companies; these companies employ PTs (and sometimes OTs) to do the evaluations. An exercise physiologist or kinesiologist without a license would not be recognized by Florida’s state boards or by insurers as an FCE provider. Notably, Florida’s motor vehicle insurance (PIP) and workers’ comp systems typically require that functional capacity/impairment evaluations be done by licensed healthcare professionals.

  • Referral Context: For physician referrals, Florida physicians refer patients to PT or OT for FCEs (or to specialized FCE centers staffed by those professionals). A PTA is never the direct referral recipient for an FCE. In the workers’ compensation context, Florida has guidelines for work hardening and FCE services which imply the use of qualified rehab professionals. Employers who need an FCE (e.g., for a difficult return-to-work case or pre-employment screening) usually engage a licensed therapist to perform it. Overall, regardless of referral source, Florida expects an FCE to be performed by a licensed PT/OT – with PTAs only in an assisting role and no independent exercise therapist involvement in official capacity.

Georgia

  • PTAs: Georgia’s laws on physical therapy clearly prohibit PTAs from performing initial patient assessments or making clinical judgments. Consequently, a PTA in Georgia cannot perform an FCE on their own. The PT must conduct the FCE, including evaluating the patient’s condition and functional limitations, administering or overseeing the necessary tests (lifting, carrying, endurance, etc.), and interpreting the findings into work/activity restrictions. A PTA may help carry out parts of the FCE if delegated (for example, monitoring a patient during a treadmill test), but Georgia requires that the PTA be under “direct supervision” for any such assistive role during evaluative processes. The final FCE report and determinations must come from the PT.

  • Exercise Therapists: Georgia does not license exercise therapists or physiologists. FCEs are typically done by PTs or occupational therapists in Georgia, especially for any formal purpose. Some occupational health or sports medicine clinics have exercise physiologists on staff who might participate in functional testing, but any official report would be issued by a licensed provider. Insurers (including Georgia’s State Board of Workers’ Compensation) rely on FCEs from licensed professionals; a report from an unlicensed “functional evaluator” would carry little weight.

  • Referral Context: Physician referrals for FCE in Georgia go to rehabilitation providers (almost always a PT or OT). The Georgia workers’ comp system often uses FCEs to determine an injured worker’s capabilities, and those FCEs are performed by certified evaluators (with backgrounds in PT/OT). An employer might request an internal “fitness test” for a job, but if it’s an official FCE, they will send the employee to a clinic. In all scenarios, Georgia does not permit PTAs or unlicensed persons to independently perform or bill for FCEs, ensuring that a qualified professional is responsible for the evaluation.

(The above pattern – PTAs not allowed to perform evaluative services, including FCEs, and FCEs being the domain of licensed PT/OT professionals – is consistent across all U.S. states. Below are additional state-specific notes or unique regulations if any.)

Hawaii

  • PTAs: Hawaii’s regulations restrict PTAs from performing examinations or re-examinations. An FCE in Hawaii must be done by a physical therapist (or other qualified professional like an OT). A PTA cannot on their own conduct the comprehensive functional testing or provide the conclusions. They may only assist under supervision. There are no special Hawaii-specific exceptions to this rule.

  • Exercise Therapists: No state licensure exists for exercise therapists in HI. FCEs are done by rehab clinics (PT/OT). No distinct rules by referral type – always a licensed provider needed.

Idaho

  • PTAs: Must work under PT direction and cannot perform patient evaluations. FCE = evaluation; thus PT only. No Idaho-specific carve-outs.

  • Exercise Therapists: Not regulated. FCEs done by PT/OT; exercise specialists might help in wellness context but not recognized for official FCE. Employers/insurers expect licensed evaluator.

Illinois

  • PTAs: Illinois law (225 ILCS 90) reserves evaluation to the PT. A PTA cannot do FCEs independently.

  • Exercise Therapists: Not licensed in IL. FCEs typically by PT/OT. Illinois workers’ comp and employers rely on licensed professionals for FCE. No unique distinctions by referral source.

Indiana

  • PTAs: Indiana practice act prohibits PTAs from initial evaluations. FCE must be by PT. PTA may assist with parts of FCE under supervision.

  • Exercise Therapists: Not licensed. FCEs done by PT/OT. Insurers and employers require licensed evaluator.

Iowa

  • PTAs: Cannot perform evaluative procedures per Iowa law. FCE by PT only.

  • Exercise Therapists: Not licensed. FCE = PT/OT domain in practice.

Kansas

  • PTAs: Kansas regs do not allow PTAs to perform initial eval or interpret data. PT must do FCE.

  • Exercise Therapists: No licensure. FCEs by PT/OT; others not accepted for formal purposes.

Kentucky

  • PTAs: Kentucky explicitly states PTAs cannot perform assessments or create discharge summaries. FCE must be PT-run. The Kentucky PT Board likely has position statements similar to NC’s (ensuring PT does FCE and PTA only assists minimally).

  • Exercise Therapists: Not licensed. FCEs done by PT/OT in KY for insurers/employers.

Louisiana

  • PTAs: Louisiana’s practice rules prevent PTAs from performing evaluations. Thus, a PTA cannot independently do an FCE (only help as directed by the PT).

  • Exercise Therapists: Louisiana is unique in that it licenses “Clinical Exercise Physiologists” under the State Board of Medical Examiners. However, the scope of that license is focused on exercise testing and cardiac/pulmonary rehab under physician supervision. Performing a broad occupational FCE is not clearly within the exercise physiologist’s scope unless perhaps specifically ordered by a physician as an exercise test. In practice, FCEs in Louisiana are still usually done by PTs or OTs. A licensed clinical exercise physiologist might participate in certain functional capacity evaluations (especially those involving graded exercise tests for cardiopulmonary capacity), but they would do so in coordination with medical oversight.

  • Referral Context: A physician referral in Louisiana could theoretically go to either a PT or a licensed clinical exercise physiologist for specific testing; however, for a comprehensive FCE of work ability, physicians and insurers use PT/OT providers. Employers may use occupational medicine clinics (with PTs) for FCE. Louisiana’s workers’ comp guidelines allow medical providers to refer for FCE; those referrals typically end up with PTs or OTs (the PTA cannot be the sole provider). The presence of a licensed Exercise Physiologist category in LA adds an additional resource for exercise tolerance evaluations, but does not replace the role of PT in musculoskeletal functional evaluations.

Maine

  • PTAs: Maine regulations do not permit PTAs to perform patient examinations or evaluations. Thus no independent FCE by a PTA. PT must do it.

  • Exercise Therapists: Not licensed. FCEs in Maine done by PTs/OTs; insurers and employers expect that.

Maryland

  • PTAs: Maryland law (Maryland PT Practice Act) restricts PTAs from evaluative duties. FCE must be conducted by PT (with PTA help only under supervision).

  • Exercise Therapists: Maryland does not license exercise physiologists. FCEs performed by licensed rehab professionals. No special rules by referral type – always need licensed person for official FCE.

Massachusetts

  • PTAs: Massachusetts regulations: PTAs cannot perform initial assessments or make clinical judgments. Therefore, no independent FCE by PTA. PT only.

  • Exercise Therapists: No licensure in MA. FCEs done by PT/OT. Insurers (including MA workers’ comp) expect reports from licensed providers.

Michigan

  • PTAs: Michigan forbids PTAs from patient evaluation or program planning. FCE = PT’s responsibility. PTA can collect data but cannot determine functional capacity on their own.

  • Exercise Therapists: Michigan does not license “kinesiologists” (despite some using that title) – only licensed PT/OT would be accepted for FCE. (Michigan does license Athletic Trainers, but ATs performing FCE would be acting outside typical scope unless working under a physician’s direction for a specific purpose.) Generally, PTs/OTs do FCEs.

Minnesota

  • PTAs: Minnesota’s statutes and board rules indicate PTAs cannot perform evaluative procedures. An FCE must be done by the PT. (Minnesota’s PT Board had even issued guidance on FCE administration to ensure proper training and standards for PTs.) PTA role limited to assisting tasks, not the evaluation itself.

  • Exercise Therapists: No licensure for exercise physiologists. FCEs are typically done by PTs or OTs in Minnesota. The Minnesota Department of Labor and Industry (workers’ comp division) recognizes FCEs as valid when done by qualified professionals, usually meaning licensed rehab therapists.

Mississippi

  • PTAs: Mississippi law (Miss. Code §73-23) – PTAs assist in treatment; evaluations are the PT’s domain. PTA cannot do FCE independently.

  • Exercise Therapists: Not licensed. FCE by PT/OT. Mississippi’s workers’ comp would require a licensed professional’s report.

Missouri

  • PTAs: Missouri regs: PTA cannot initiate or modify treatment plans, which implies they cannot perform evaluations. FCE by PT only.

  • Exercise Therapists: No license for exercise phys. FCE by PT/OT for formal purposes.

Montana

  • PTAs: Montana rules preclude PTAs from patient assessment; thus PT only for FCE.

  • Exercise Therapists: Not licensed. FCE done by licensed providers.

Nebraska

  • PTAs: Nebraska – PTAs cannot perform evaluative activities; FCE must be done by PT.

  • Exercise Therapists: Not licensed. Use of PT/OT for FCE.

Nevada

  • PTAs: Nevada’s PT Board regulations state PTAs may not perform initial examinations or re-evaluations. FCE is a specialized exam, so PT must do it.

  • Exercise Therapists: Not licensed. FCE via PT/OT. Nevada employers/insurers adhere to using licensed professionals.

New Hampshire

  • PTAs: NH practice act – PTA cannot do initial patient assessments. No PTA-led FCE.

  • Exercise Therapists: Not regulated. FCE by PT/OT.

New Jersey

  • PTAs: NJ law prohibits PTAs from performing evaluations. FCE by PT only. New Jersey also has specific regulations about supervision ratios for PTAs, ensuring PT is in charge of any evaluative service.

  • Exercise Therapists: NJ does not license exercise physiologists. FCEs for insurance/employment are done by PT or OT.

New Mexico

  • PTAs: NM – PTAs cannot perform evaluative or discharge processes. FCE must be PT.

  • Exercise Therapists: Not licensed. FCE by PT/OT.

New York

  • PTAs: New York State law is explicit that PTAs work under the direction of PTs and cannot perform initial evaluations or alter the plan of care. Therefore, a PTA in NY cannot conduct an FCE independently. The PT must perform the functional evaluation. (NY also requires direct supervision of PTAs in most settings which means a PT would be readily available during any FCE assistance.)

  • Exercise Therapists: New York does not license exercise physiologists or similar. FCEs in NY (for workers’ comp, no-fault insurance, etc.) are typically done by PTs or OTs. The New York State Insurance Fund and other insurers expect FCE reports signed by licensed professionals. An exercise specialist’s evaluation might be used informally by an employer, but it wouldn’t carry legal weight in a claim.

  • Referral Context: Physician referrals (e.g. after an injury, for disability determination) for FCEs in NY will go to a PT or OT. The workers’ compensation board sometimes mandates an FCE; those must be performed by qualified providers from approved facilities (again, PT/OT). An employer could have an in-house functional test administered by, say, a fitness instructor, but any decisions around reasonable accommodation or disability would still hinge on medical/FCE reports by clinicians. Thus, in New York, regardless of who requests the FCE, the actual evaluation should be done by a licensed PT or OT, not a PTA or unlicensed person.

North Carolina

  • PTAs: North Carolina has a detailed position statement on PTAs assisting with FCEs. It is the position of the NC Board that an FCE must be performed by a PT – the PT must first assess the patient’s condition to ensure it’s safe to proceed, and the PT is responsible for interpreting all data. A PTA may assist the PT during an FCE, but with significant limits: “When assisting with the performance of an FCE, a PTA cannot perform tests of cardiovascular or pulmonary capacity, observations of integumentary changes, or assessments of musculoskeletal or neuromuscular function”. An appropriately trained PTA in NC may handle objective, non-interpretive tasks – e.g. recording range-of-motion or strength measurements – and can observe whether a patient’s performance is safe/correct. All evaluative judgments (like determining maximum effort, functional limitations, or ability to work) must be made by the PT. In summary, NC allows PTA involvement in FCEs only under direct PT supervision and only for clearly defined tasks; a PTA cannot independently conduct or conclude an FCE in North Carolina.

  • Exercise Therapists: North Carolina does not license exercise physiologists; FCEs are typically done by PTs or OTs. However, NC has many private occupational rehab companies – some employ “exercise specialists” or kinesiologists as ancillary staff. Such staff might help run parts of a work conditioning or FCE protocol, but the primary evaluator must be a licensed practitioner. For instance, an exercise physiologist might monitor a cardiovascular endurance test as part of an FCE team, but the overall FCE report in NC would be issued by the supervising PT.

  • Referral Context: Physician referrals for FCE in NC go to PTs (often those with Occupational Health or Ergonomics specialization). Employers or insurers (like workers’ comp carriers) that request FCEs also use providers that employ PTs/OTs. Given the NC Board’s strict guidance, any FCE done in the scope of PT must have a PT in charge – even if an employer were to ask a non-licensed person for a “functional test,” that person could not present it as an FCE in the medical/legal sense. North Carolina’s workers’ compensation rules typically require FCE reports from credentialed experts, which in practice are PTs or OTs (NC OTs also perform FCEs for vocational rehab). PTAs and unlicensed exercise personnel do not qualify as independent experts in this context.

North Dakota

  • PTAs: North Dakota regulations follow the standard model: PTAs cannot perform patient evaluations or alter care plans. Thus, an FCE, being an evaluation of function, must be performed by a PT. PTA involvement can only be auxiliary.

  • Exercise Therapists: No licensure for exercise physiologists. FCEs by PT/OT. No unique state differences in referral; as elsewhere, physician or insurer requests go to PTs.

Ohio

  • PTAs: Ohio explicitly confirms that “a physical therapist assistant (PTA) cannot perform a functional capacity evaluation since they are evaluative in nature and may only be performed by a physical therapist.” This is stated in the Ohio Occupational Therapy, Physical Therapy, and Athletic Trainers (OTPTAT) Board’s scope-of-practice FAQ, leaving no ambiguity. The PTA’s role is limited to treatment implementation; all evaluative services, including FCEs, are reserved for the PT in Ohio. (Ohio Admin Code rule 4755:2-2-03 also enumerates that PTAs are not qualified to conduct initial patient evaluations or re-evaluations.)

  • Exercise Therapists: Ohio does not license exercise therapists or kinesiologists. FCEs are generally done by PTs or OTs. The state’s Bureau of Workers’ Compensation (BWC), for example, will pay for an FCE as part of rehab services, but requires it be done by qualified providers (typically PTs/OTs). An unlicensed exercise physiologist would not meet BWC’s provider criteria for an official FCE.

  • Referral Context: In Ohio, any FCE ordered by a physician or the BWC will be scheduled with a PT/OT. A PTA cannot accept an FCE referral nor bill for an FCE. If an employer in Ohio wants a functional test done, they likewise turn to therapy clinics or occupational health providers. The clear rule from the OTPTAT Board means that for all practical referrals (medical, insurance, or employer), the expectation is a physical therapist performs the FCE, potentially assisted by a PTA only in a subordinate capacity.

Oklahoma

  • PTAs: Oklahoma’s PT Practice Act restricts PTAs from evaluative activities. Therefore, a PTA in Oklahoma cannot independently perform an FCE. The PT must conduct the evaluation of functional capacity. PTA may help with routine aspects under supervision but cannot lead or interpret the FCE.

  • Exercise Therapists: No state license for exercise phys. FCEs by PT/OT. Oklahoma’s workers’ comp system expects FCEs from licensed rehab professionals. No special distinctions; same pattern as other states.

Oregon

  • PTAs: Oregon regulations (and the Oregon PT Licensing Board) stipulate that PTAs do not perform patient assessments; that duty lies with PTs. Hence, a PTA cannot do an FCE on their own in Oregon. The PT must evaluate and direct all such assessments.

  • Exercise Therapists: Oregon does not license exercise therapists. FCEs are typically done by PTs/OTs. For instance, Oregon’s Worker’s Compensation Division has certified vocational/medical providers for such evaluations, normally PTs or OTs.

  • Referral Context: Regardless of referral source in Oregon, a licensed PT or OT is required to perform the FCE. PTAs or non-licensed individuals are not considered qualified FCE examiners by employers or insurers.

Pennsylvania

  • PTAs: Pennsylvania law prevents PTAs from performing evaluations or making clinical judgments about the patient. Consequently, a PTA is not permitted to perform FCEs independently. A PT must perform the FCE in PA. The State Board of Physical Therapy would view an unsupervised PTA conducting an FCE as practicing beyond their scope.

  • Exercise Therapists: Pennsylvania does not have licensure for exercise physiologists. FCEs are normally administered by PTs or OTs. Some large employers in PA (e.g., in manufacturing) have “work hardening” programs where exercise specialists might coach patients, but any formal FCE is done by licensed therapists.

  • Referral Context: Physicians or insurers in PA will refer patients for FCEs to rehab facilities (PT/OT). Employers use those same resources for objective FCEs when needed. The PTA cannot be the provider-of-record for an FCE in any of these cases.

Rhode Island

  • PTAs: Rhode Island’s PT regulations align with the APTA guidelines – PTAs cannot perform initial evaluations or assessments. Thus, no independent FCE by a PTA. PT must do it, PTA can assist.

  • Exercise Therapists: Not licensed in RI. FCE by PT/OT. Standard practice applies.

South Carolina

  • PTAs: South Carolina explicitly requires that evaluations be done by PTs. A PTA may not conduct an evaluation like an FCE. The SC Board of PT Examiners would consider it out of scope for a PTA.

  • Exercise Therapists: SC does not license exercise physiologists. FCEs are done by PT/OT (often those with ergonomic specialty). No unique provisos; similar to general practice.

South Dakota

  • PTAs: SD – PTAs cannot do patient assessments; FCE must be PT-led.

  • Exercise Therapists: No licensure. FCE by PT/OT.

Tennessee

  • PTAs: Tennessee’s rules prohibit PTAs from performing examinations, evaluations, or re-evaluations. Therefore, a PTA cannot perform an FCE. The PT must carry out the functional evaluation and make all related determinations.

  • Exercise Therapists: Tennessee does not license exercise physiologists. FCEs are performed by licensed providers (PT/OT). The TN workers’ comp system and employers rely on those professionals for FCEs.

Texas

  • PTAs: Texas law is very clear that physical therapy treatment may not begin until a PT has completed an evaluation. PTAs in Texas may not perform the initial evaluation or any act of diagnostic interpretation. In terms of FCE, Texas follows the rule that it is an evaluative service – only the PT can perform it. The Texas Board of PT Examiners expects that a PTA’s role in any evaluative process is strictly limited to data collection under direct PT instruction, and not any independent component. (Texas Administrative Code §322.1 emphasizes the PT must do the evaluation; PTAs can only “screen” in a very limited, preset way, and cannot determine if further intervention is needed.) Practically, a PTA in Texas should not be the one administering an FCE unless a PT is present and directing throughout, and even then the PT signs off on all results.

  • Exercise Therapists: Texas does not license exercise physiologists (there have been no state licenses beyond PT/OT for this function). FCEs in Texas are commonly performed by PTs or OTs with specialized FCE training, especially within the workers’ comp system. Texas has specific Workers’ Compensation Medical Fee Guidelines for FCEs, which discuss billing and elements of the FCE, implicitly assuming a qualified health care provider is performing the service. While the guideline doesn’t list allowed providers in that section, elsewhere the Division of Workers’ Compensation typically recognizes PTs, OTs, or sometimes chiropractors for similar functional evaluations. An unlicensed exercise therapist would not be an accepted provider for a DWC-ordered FCE.

  • Referral Context: Physician referrals in Texas for FCE go to PTs (or OTs). Texas is a direct access state with limitations, but FCEs often come after a referral or order. If an employer requests an FCE (say, a fit-for-duty exam for an injured worker returning), they will contract a clinic or therapist – they would not assign it to a PTA alone, as it wouldn’t be valid. Insurers/workers’ comp in Texas require documentation by the treating or evaluating practitioner (e.g., the PT) for it to count. In sum, across referral types, Texas requires that a licensed PT (or other recognized professional) perform the FCE, with no independent PTA evaluations allowed.

Utah

  • PTAs: Utah’s practice act indicates PTAs cannot perform patient assessment or clinical evaluation. Therefore, a PTA cannot do an FCE in Utah. Only a PT (or similarly qualified professional) can.

  • Exercise Therapists: No licensure. FCE by PT/OT in Utah.

Vermont

  • PTAs: Vermont – PTAs are not allowed to perform initial evaluations. Thus, FCE must be done by PT.

  • Exercise Therapists: Not licensed. FCE via PT/OT.

Virginia

  • PTAs: Virginia regulations state PTAs cannot perform evaluations or re-evaluations. FCE falls to PT.

  • Exercise Therapists: No license in VA. FCE done by PT/OT.

Washington

  • PTAs: Washington State law requires PTs to do the evaluation; PTAs cannot independently evaluate or alter treatment programs. So a PTA cannot perform an FCE alone in WA. PT must be responsible for it.

  • Exercise Therapists: Washington does not license exercise physiologists. FCEs (especially in the context of WA’s Dept. of Labor & Industries for workers’ comp) are done by PTs or OTs often certified in FCE. Unlicensed individuals are not accepted as evaluators for official FCE reports.

West Virginia

  • PTAs: West Virginia’s Board of PT has addressed this in Q&A format: a PTA cannot perform an FCE in a physical therapy setting – it’s beyond their scope (this mirrors Ohio’s statement and others). Only the PT can conduct and finalize an FCE in WV.

  • Exercise Therapists: No licensure. FCE by PT/OT. WV employers/insurers rely on licensed practitioners for FCEs.

Wisconsin

  • PTAs: Wisconsin prohibits PTAs from initial evaluations or making clinical judgments. Thus, a PTA cannot perform an FCE; a PT must do it.

  • Exercise Therapists: Wisconsin does not license exercise physiologists; FCEs are done by PT/OT. No special differences – standard practice applies.

Wyoming

  • PTAs: Wyoming’s rules indicate PTAs function under PT supervision and cannot perform evaluations or modify treatment goals. So a PTA cannot independently do an FCE in Wyoming; the PT is responsible for the evaluation.

  • Exercise Therapists: No licensure for exercise therapists. FCEs are handled by PT/OT in Wyoming as elsewhere.

Disclaimer:This article is provided for informational purposes only and does not constitute legal, regulatory, or professional advice. Scope-of-practice laws and regulations governing Functional Capacity Evaluations (FCEs) vary by country, state, and profession, and are subject to change. Readers should consult relevant licensing boards, regulatory authorities, or legal counsel to verify current requirements in their jurisdiction before providing or delegating FCE services.

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