Revenue Cycle

Physician supervision clarification still causing confusion

Recovery Auditor Report, December 15, 2011

In the calendar year (CY) 2012 OPPS Final Rule, CMS once again amended the regulations for supervision of hospital services, and once again CMS seems to have made unclear clarifications that are stirring up controversy.  The crux of the confusion is around its amendment of 410.27, the regulation containing coverage requirements for hospital outpatient therapeutic services furnished incident-to a physician’s service. CMS expanded the definition of incident-to services to include all services that are not diagnostic.

Previously, the regulation appeared to be limited to services provided incident to a physician’s service and covered under a specific provision of the Social Security Act that describes coverage of hospital outpatient departments services provided incident to.  This limitation seemed to indicate that other services such as physical therapy (PT), occupational therapy (OT) , speech language pathology and radiation therapy, which are covered under other provisions, did not have to meet the requirements in 410.27, most notably the supervision requirements.

Continue reading Kimberly Hoy’s note on the MedicareMentor blog, and stay tuned to the Revenue Cycle Institute for the release of a white paper that takes an in-depth look at physician supervision.

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