All the comments and blogging about supervision rules in Radiation Oncology settings are causing a “buzz” in centers across the country. Whether freestanding or hospital based, the need to stay current with coding regulations, particularly pertaining to CMS is paramount. Discussions within the Radiation Oncology community with regards to the 2010 and 2011 changes regarding supervision raise questions . We at Radmax, LTD, wanted to take a moment to refresh those in the field of the current three levels of supervision required for correct and compliant reimbursements.
The level of supervision required for each produre is published by CMS as a part of the Medicare Physician Fee Schedule. To determine the level of supervision for a specific HCPCs or CPT code, please refer to the fee schedule look up page of the CMS website at the following address:
In the final outpatient rule for 2010, CMS required direct supervision for all outpatient therapeutic services and defined direct supervision as requiring a physician or non-physician practitioner to be present on the same campus and immediately available to furnish assistance and direction throughout the performance of the procedure.
The CY 2011 rule, CMS revised the definition of direct supervision for all outpatient therapeutic services to remove all references to the physical boundaries within which the supervising physician or Non-Physician Practitioner (NPP) must be located.
The regulation defines the levels of physician supervision for as follows:
General supervision: means the procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure.
Direct supervision: It does not mean that the physician must be present in the room when the procedure is performed. Requires immediate availability, meaning physically present, interruptible and able to furnish assistance and direction through the performance of the procedure, but without reference to any particular physical boundary. This new definition will now apply equally in the hospital or in on-campus or off-campus provider-based departments.
Personal supervision: means a physician must be in attendance in the room during the performance of the procedure.