Anyone have a link for the actual Medicare Supervision Requirement guideline? I was not aware that there is now a requirement..I had read ASTRO's guideline, but not aware of anything official from CMS?
There is nothing much new with CMS requirement - they still require a radiation oncologist or "non-physician" practitioner.
CMS defers to hospital credentialing bodies to determine what is appropriately trained non-physician practitioner. The CMS language is below. However, do note that there has been a HUGE increase in the number of whistleblower cases brought up in the last 24 months where rad onc groups had to pay back millions for lack of supervision. In addition, I was told by my biller that an ASTRO rep at a recent billing conferences heavily implied some sort of statement regarding supervision will be issued by ASTRO soon, helping to clarify the issue; off-the-record discussion is leaning toward eliminating any gray area - ie ASTRO is likely supporting a clear cut solution that a rad onc must be physically present for all treatments.
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"In the CY 2010 OPPS/ASC final rule with comment period, we finalized our proposal to allow, in addition to clinical psychologists, certain other nonphysician practitioners to directly supervise services that they may perform themselves under their State license and scope of practice and hospital-granted or CAH-granted privileges. The nonphysician practitioners that were permitted to provide direct supervision of therapeutic services under the CY 2010 OPPS/ASC final rule with comment period are physician assistants, nurse practitioners, clinical nurse specialists, certified nursemidwives, and licensed clinical social workers. These nonphysician practitioners may directly supervise outpatient therapeutic services that they may personally furnish in accordance with State law and all additional requirements, including the Medicare coverage rules relating to their services specified in our regulations at 42 CFR 410.71, 410.73, 410.74, 410.75, 410.76, and 410.77 (for example, requirements for collaboration with, or GENERAL supervision by, a physician)."
"In the CY 2010 OPPS/ASC final rule with comment period, we also finalized our proposal to add paragraph (a)(1)(iv)(B) to §410.27. This paragraph updated our previous regulation at §410.27(f) to reflect that, for off-campus PBDs of hospitals, the physician or nonphysician practitioner must be present in the off-campus PBD, as defined in §413.65, and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician or nonphysician practitioner must be in the room when the procedure is performed. In addition, we finalized the proposed technical change to clarify the language in §410.27(f) by removing the phrase “present and on the premises of the location” and replacing it with the phrase “present in the off-campus provider-based department.”
http://www.wsha.org/files/83/Physician_Supervision_Proposed_Rule.pdf
Page 407-409
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Here is also an excellent journal article about recent whistleblower/supervision cases and issues.
http://www.appliedradiationoncology...act-allegations-against-radiation-oncologists