Health Information Management

Q&A: Physician supervision for chemotherapy

APCs Insider, January 25, 2013

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Q: I have a question about physician supervision for a cancer center that is not in the hospital, but is on the hospital campus. The oncologist orders chemotherapy, but oncologists are not always in the cancer center when the chemotherapy is being administered. What type of supervision would be required?

A: The type is going to be direct supervision. CMS has not moved chemotherapy down to general supervision and has not specified any services for personal supervision on the therapeutic side. 
When you think about the definition of direct supervision, you have to then find someone who can be immediately present. So they don’t have to be in the cancer center if it’s a building sort of across the street from the hospital and a quick little jog over there. It takes somebody less than five minutes to run over there. So someone at the main hospital could provide that supervision.
Then you get into the question, “Are they appropriate to step in?” That's where it gets difficult. So if the oncologist happens to be over at the main hospital, you're probably golden.
But often in these cancer centers, the oncologists are somewhere else. They went to another city to provide cancer care in another city and they split their time between different cities if you're in a rural area. If they are not around or their practice is across town, you're going to have to have a physician who is competent to provide the supervision to provide the chemotherapy.
Some hospitals have credentialed their hospitalists to do that. If the hospitalists are not comfortable providing that supervision, you have to look to other providers. Some hospitals have nurse practitioners who worked with their oncologists and normally wouldn't be ordering the chemotherapy on their own but nevertheless are very familiar with the patients and with the chemotherapy regimens. Those facilities added some special credentialing for those folks to be able to supervise the chemotherapy because of their familiarity with the drugs and the patients, etc., because they specifically worked within that practice.
They were nurse practitioners that specifically worked within the oncology practice. So direct supervision is going to be the right answer for the level of supervision but you also have to look at who can provide it and where they need to be.
Editor’s note: Kimberly Anderwood Hoy, JD, CPC, director of Medicare and compliance for HCPro, Inc, in Danvers, Mass, answered this question.

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