Health Information Management

Tip: Meeting the new physician supervision requirements

APCs Insider, January 7, 2011

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CMS’ decision to back away from the boundary requirement for physician supervision provides hospitals with more options for how and when they deliver services. However, the onus is still very much on hospitals because, if audited by CMS, RACs, or others, they will need to prove who the supervisory physician or nonphysician practitioner (NPP) was and how that person met the requirement of being immediately available, including that he or she could be interrupted.

In order to meet the challenges of 2010 final rule, the medical staff and compliance officers reviewed scheduling patterns to come up with staffing solutions that would not compromise the delivery of patient care while meeting the CMS regulations. CMS’ deletion of “in the hospital” from the supervision requirements will enable facility staff members to see who is available in the clinic setting as well.

Each facility will have different criteria and different staffing situations, so no one-size-fits-all solution exists. When determining whether your facility meets supervision requirements, consider the following and other relevant questions:

• Who is responsible and on which days?
• What are the department’s hours of operation?
• How will staff contact the supervising practitioner if he or she is not in the department?
• What is the expected response time?
• What are the limitations of where the supervising practitioner can go when he or she is responsible for supervision?

This tip was adapted from “CMS tears down walls for physician supervision” in the January issue of Briefings on APCs.

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