ACR Radiology Coding Source™ November-December 2008 Physician Supervision Requirements
The ACR has received many questions related to physician supervision in hospitals and provider-based departments of hospitals. These questions have arisen because of a recent clarification of Medicare policy by the Centers of Medicare and Medicaid Services (CMS) in the Hospital Outpatient Prospective Payment System (HOPPS) proposed and final rules for calendar year (CY) 2009.1,2 CMS included a discussion of physician supervision requirements in these rules to provide an “up-to-date clarification of the existing policy.” The ACR and other stakeholders are concerned that CMS has not provided an up-to-date clarification of the existing policy but rather an expansion of policy without the opportunity to provide public comment. Nonetheless, we believe it is important for radiologists to be aware of the latest CMS interpretations of the physician supervision rules and we provide them in this article. In addition, we include a brief summary of previous CMS guidance that supports our position that CMS has issued new policy.
Physician Supervision Requirements in the Hospital Outpatient Setting 2009 Hospital Outpatient Prospective Payment System Regulation