Revenue Cycle

CMS finalizes physician supervision proposals

Medicare Update for CAHs, November 30, 2011

When the 2012 outpatient prospective payment system (OPPS) proposed rule was released, there were a few items of interest for critical access hospitals (CAHs) related to physician supervision for outpatient therapeutic (non-diagnostic) services, says Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc.

In the rule, CMS proposed that CAHs would get another “waiver” for 2012, but that CAH representatives would be added to the independent advisory review entity,” which helps to review the supervision level for a given service.  This expert panel, which may consist of up to 15 representatives of providers (currently employed full-time, not as consultants, in their respective areas of expertise) subject to the OPPS, reviews clinical data and advises CMS about the clinical integrity of the APC groups and their payment weights, according to CMS.

In the 2012 OPPS final rule, these proposals became finalized. CMS added representation from small rural PPS hospitalhospitals with 100 of fewer beds and either geographically located in a rural area or paid under the hospital OPPS with a rural wage index—and representation from CAHs to represent their interests to the panel. This means enforcement of direct supervision will once again be waived for these two separate sets of providers for one more year as the panel discusses the matter further.

Most commenters were in favor of the proposal to use the APC panel, provided that CAHs and small rural PPS hospitals were in fact given appropriate representation, according to the final rule. Many commenters requested that CMS add four CAH representatives and four small rural PPS hospital representatives to the current panel of 15. CMS agreed with the suggestion that the entities be added to the panel, but decided to add two CAH representatives and two small rural PPS hospital representatives instead of four of each.

“No other immediate changes were made to the direct supervision requirements for outpatient therapeutic (non-diagnostic) services for critical access hospitals, but the additional representation on the APC Advisory Panel and the eventual enforcement of direct supervision for CAHs and small rural PPS hospitals is something that providers should monitor closely as it unfolds in 2012,” says Mackaman.

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