Does anyone have the actual 100% clear idea if IGRT imaging can be billed when the physician is off site? Does APP presence count? I heard yesterday the dates for any rule changes were pushed back but this is here say. Is there a resource to say that commercial payers do not audit this but medicare does?
CBCT General/Direct Supervision
- Thread starter xrt123
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deleted1168505
You could always call bridge oncology
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*cracks knuckles*
No one on planet Earth has 100% clarity on this.
To my knowledge, direct supervision is still required in freestanding clinics.
In hospital outpatient environments, general supervision has been kosher since January 1st, 2020.
ASTRO and others did backbends to claim that IGRT is actually a diagnostic test, and to bill the professional component of IGRT in the outpatient setting, the ordering physician (RadOnc) still needs to directly supervise.
Many of us disagree but - it doesn't matter, because then COVID happened, and virtual supervision was allowed.
This is in effect through at least the end of 2023:
I think this was updated again so it's actually through the end of 2024 but I can't find that right now.
At the very least, in the hospital outpatient setting, if you can Facetime your staff, you're good.
2023 or 2024 dates aside, the point being this is currently a continuation of the temporizing measure from the start of the pandemic. It's likely it will become a "forever rule", but that hasn't been done yet.
Now, for commercial audits, hoo boy - ask for the moon while you're at it.
You're have to go carrier by carrier for your region for that one. Audits haven't been a thing for awhile for a couple reasons, at least not that I've heard about.
And man - what a mess that might be if/when someone attempts the first audit. Everything that's happened between 2019 and now - even if someone was clearly "wrong", outside of grossly intentional fraud, there's a "good faith" argument to be made about everything.
No one on planet Earth has 100% clarity on this.
To my knowledge, direct supervision is still required in freestanding clinics.
In hospital outpatient environments, general supervision has been kosher since January 1st, 2020.
ASTRO and others did backbends to claim that IGRT is actually a diagnostic test, and to bill the professional component of IGRT in the outpatient setting, the ordering physician (RadOnc) still needs to directly supervise.
Many of us disagree but - it doesn't matter, because then COVID happened, and virtual supervision was allowed.
This is in effect through at least the end of 2023:
I think this was updated again so it's actually through the end of 2024 but I can't find that right now.
At the very least, in the hospital outpatient setting, if you can Facetime your staff, you're good.
2023 or 2024 dates aside, the point being this is currently a continuation of the temporizing measure from the start of the pandemic. It's likely it will become a "forever rule", but that hasn't been done yet.
Now, for commercial audits, hoo boy - ask for the moon while you're at it.
You're have to go carrier by carrier for your region for that one. Audits haven't been a thing for awhile for a couple reasons, at least not that I've heard about.
And man - what a mess that might be if/when someone attempts the first audit. Everything that's happened between 2019 and now - even if someone was clearly "wrong", outside of grossly intentional fraud, there's a "good faith" argument to be made about everything.
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Correct, tele option available, requires a/v real time communication/availability
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And how would you prove, retroactively, that such A/V capability was or was not available?
yeah, thats a loser from a prosecution standpoint. unless someone qui tam's themselves into obliteration, it just ain't gonna happen.
plus the pro fee on IGRT Is a measly what $30 ?
If the qui tam is for 50k, its not worth picking up the phone. Across 5 centers with 1000 patients a year and obvious, egregious abuse in the freestanding setting? Maybe. I mean, why not just hire an NP to hang around..
IGRT: When you need to sell software compliance stuff (hi Ron) make this a huge scary story
yeah, thats a loser from a prosecution standpoint. unless someone qui tam's themselves into obliteration, it just ain't gonna happen.
plus the pro fee on IGRT Is a measly what $30 ?
If the qui tam is for 50k, its not worth picking up the phone. Across 5 centers with 1000 patients a year and obvious, egregious abuse in the freestanding setting? Maybe. I mean, why not just hire an NP to hang around..
IGRT: When you need to sell software compliance stuff (hi Ron) make this a huge scary story
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