Corporate Compliance

Physician must be present when monitoring HBO therapy

Compliance Monitor, October 28, 2005

QUESTION: Can you please clarify if there are any explicit guidelines as to who can monitor patients undergoing hyperbaric oxygen (HBO) therapy for wound therapy (technician or registered respiratory therapist)? I believe that the physician must be present during the entire session, but does a physician need to perform these services or is a technician sufficient? I have referenced CMS Transmittal PM AB-02-183, but all it states is "physician attendance and supervision."

ANSWER: Yes, explicit guidelines exists as to who can monitor patients undergoing HBO therapy. The last revision of the Hyperbaric Oxygen Therapy LCD (June 28, 2004) states that "Direct supervision means that physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure (42 CFR 410.32)." HBO therapy rendered within a hospital outpatient department is considered "incident to" a physician's (MD/DO) services and requires physician supervision.

It is presumed the physician supervision requirement is met when services are performed on the hospital premises; however, in all instances, it is recommended that the physician be present during the ascent and descent portions of each treatment. For HBO therapy performed at an off-campus hospital site or other non-hospital setting, the physician must be present in the office suite.

The Undersea and Hyperbaric Medical Society recommends personal physician supervision during all critical and key portions of HBO therapy (see Grinstead, "Formal Request for National Coverage Decision-Physician Attendance During Hyperbaric Oxygen Treatments," September 21, 2000). Personal supervision is defined as physician presence at the chamber.

According to the guidelines (and there is a lot more good information in this LCD), we have concluded that the physician must be present for the "critical and key portions" of the treatment as well as any emergencies that might arise. In most hospitals the entire session is monitored by the HBO therapy department with the physician present for the key portions-and close by at all times.

You can find a good discussion on this subject at this Web site. The American College of Hyperbaric Medicine specifically outlines the scope of work that an HBO therapy physician is expected to provide during the treatment session.

(Paula Schalen, CPC, APC Coordinator for St. Joseph Medical Center in Reading, PA, answered this week's question).

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