Health Information Management

Q/A: Changes to direct physician supervision

APCs Insider, December 10, 2010

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Q: Did CMS make any changes regarding the requirements of direct physician supervision?

A: CMS made no changes regarding direct physician supervision for diagnostic services. The level of supervision is dictated by the physician fee schedule and requires direct oversight by a physician.  However, during CY 2010, providers bombarded CMS with information concerning operationalizing the definition of direct physician supervision for therapeutic services regarding "in the hospital or CAH" and "in the provider based department". 

CMS listened and changed the definition by removing references to physical boundaries.  CMS removed references to "on the same campus,"  "in the off-campus provider-based department of the hospital" and "in the hospital or CAH" from the definition.  This allows supervising physicians/practitioners to be in locations close to the hospital but not in actual hospital space

CMS now defines direct supervision as "the physician or nonphysician practitioner must be immediately available to furnish assistance and direction throughout the performance of the procedure.  It does not mean that the physician or nonphysician practitioner must be present in the room when the procedure is performed." 

CMS' intent is to allow flexibility for the provision of the supervision, but it is not changing the requirement that practitioners be immediately available. This means “that the supervisory practitioner must be physically present and interruptible," and that CMS  doesn’t  expect practitioners to be physically present for services they supervise.

Editor’s note: Denise Williams, RN, CPC-H, Director of Revenue Integrity Services for Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

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