Corporate Compliance

Note: Just one week left to submit comments on the 2011 OPPS proposed rule!

Medicare Insider, August 24, 2010

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Editor’s note: Judith Kares, JD, CPC, regulatory specialist for HCPro, Inc., is the author of this week’s note from the instructor.

With just one week left to submit comments on the OPPS Proposed Rule for CY 2011, this seems a good time to review the key provisions.  The most controversial proposal is a relaxation of the physician supervision requirements (as revised in the CY 2010 OPPS Final Rule) for certain outpatient therapeutic services. 

Under this proposal, CMS would create a new category of service (“nonsurgical extended duration therapeutic services”), which would require direct supervision only during the “initiation” of the services, after which general supervision would be sufficient.  Services included in the new category are limited to observation, as well as, therapeutic infusion, push and injection, services.  Chemotherapy and blood transfusion services are excluded, based upon CMS’ belief that these services “require the physician’s physical presence in order to evaluate the patient’s condition in the event it is necessary to redirect the service.”

Continue reading Judith's note on the MedicareMentor Blog.



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