January 16, 2020

ACR Expresses Concerns About Weakened Supervision Standards for NPPs

In a Jan. 15, 2020, letter to the Centers for Medicare and Medicaid Services (CMS), the American College of Radiology® (ACR®) has described the rationale for its reservations about the growing erosion of legal requirements for direct physician supervision of physician assistants (PAs) and other non-physician practitioners (NPPs) who perform medical imaging.

Though the ACR believes PAs and NPPs are valuable members of physician-led health teams, it cautioned the Agency that loosening physician supervision requirements for them, either through Medicare regulation or decreasingly restrictive state laws and scope of practice policies, would lead to reduced patient safety and poorer quality of care for Medicare beneficiaries who receive radiology services.

To ensure adequate safety and quality standards, the ACR emphasized the need for NPPs to practice under the direct supervision of a physician. “The thorough training physicians received is essential for equipping them to oversee/supervise care and, in the case of radiologists, selecting the most appropriate radiology examination for the patient, interpreting and performing radiology procedures, accurately diagnosing patients, and minimizing unnecessary tests,” the ACR wrote.

The ACR previously submitted comments on CMS’s proposals related to scope of practice, supervision requirements and licensure requirements within the calendar year (CY) 2020 Hospital Outpatient Prospective Payment System proposed rule and the CY 2020 Medicare Physician Fee Schedule proposed rule.

Comments and questions may be directed to ACR Economics policy analyst Christina Berry at cberry@acr.org.