Health Information Management

Tip: Distinguish between CoP, OPPS requirements for physician supervision

APCs Insider, May 28, 2010

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CMS announced it will not enforce the “direct supervision” requirement for therapeutic services furnished in calendar year 2010 to outpatients in critical access hospitals (CAHs) in a March 15 agency notice to Congress.

The Medicare Conditions of Participation (CoP) for CAHs are slightly different than those for acute care OPPS hospitals. One of the main differences is CAHs don’t need to have a physician present on the campus at all times.

Pursuant to the CAH CoP, a physician has 30 minutes to arrive at the facility in an emergency. According to the CoP, the physician on call must be immediately available by telephone or radio contact, and available onsite within specific timeframes.

The final 2010 hospital OPPS rule included a direct supervision policy requiring a supervisory physician or nonphysician practitioner to be present on a hospital or CAH campus and immediately available to provide assistance and direction throughout the duration of procedures when outpatient therapeutic services are performed.

For services provided in the hospital or in designated on-campus provider-based departments, the supervising practitioner needs only to be on the campus, not in the department. However, many CAHs don’t have physicians or NPPs on the campus at all times.

This tip was adapted from “CAHs get a break on physician supervision rules for 2010” in the June issue of Briefings on APCs.

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