Health Information Management

Tip: ED physicians can provide supervision if immediately available

APCs Insider, January 21, 2011

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Over the years, many HIM staff have assumed that ED physicians in the hospital could provide the necessary direct supervision for outpatient procedures. In the 2011 OPPS final rule, CMS discusses how an ED physician could be the individual who provides direct supervision, but that each hospital needs to evaluate this. Don’t just assume that ED staff members are always immediately available in accordance with CMS guidance.

Consider this situation. A small hospital has one ED physician on staff and an ambulance arrives in the middle of the night. The ED physician is now busy and un likely to be able to interrupt the task at hand to provide direct supervision to an observation patient who has taken a turn for the worse or another patient who has a reaction to medication.
Depending on the services your facility provides, when it provides them, existing staff, and the capacity of the ED and other departments, you may be able to designate an ED physician as the supervisory physician or NPP, especially after hours. However, the ED may be too busy to respond to requests from other departments to provide the necessary supervision during daytime hours.

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

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