Health Information Management

Q/A: Changes in supervision levels for outpatient therapeutic services

APCs Insider, July 13, 2012

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Q:  In the calendar year (CY) 2012 final OPPS rule, CMS noted that the APC Panel would be making changes to the supervision levels for outpatient therapeutic procedures.  Will this information be part of the proposed rule for the next calendar year so providers can submit comments?

A:  In the CY 2012 OPPS final rule, CMS established a process for consideration of the appropriate level of supervision for outpatient therapeutic services.  The APC Panel is the advisory group that reviews requests from providers and/or CMS and makes a recommendation based on the review; the final decision regarding any change lies with CMS.   This process was described and established as part of the OPPS rule, but is actually a subregulatory process.  In the CY 2012 OPPS final rule, CMS noted: 
Therefore, we are finalizing our proposal to issue our decisions based on Panel recommendations at the subregulatory level. We will post our preliminary decisions on the OPPS Web site for public review and comment. Given that the issues will be service specific and therefore narrow, we will allow for a 30-day public comment period. We will give careful consideration to the comments that we receive, and we anticipate finalizing decisions within 60 days of the end of the comment period. Our final decisions will be effective either in July or January following the most recent APC Panel meeting.
The APC Panel reviewed the first round of requests during its February meeting and made recommendations to CMS.  In April, CMS posted its preliminary decisions based on these recommendations on the OPPS website for public comment.  On May 22, CMS posted the final decision regarding supervision levels for the selected services.  
Most of the services brought to the panel were mental health/psychotherapy services; however, some bladder catheterization procedures (CPT® 51701), immunization administration services (CPT 90471, 90472, 90473. 90474) and the services related to smoking cessation (CPT 99406, 99407) were also presented.  These services did see a change in the level of physician supervision required from direct to general supervision.  The change in supervision level became effective July 1.


Editor’s note: Andrea Clark, RHIA, CCS, CPCH, chairman, CEO, and founder of Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

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