Oncology & Hematology Coding Alert

Question: Our physicians sign their own chemotherapy orders. However, one of our physicians has stated that it is a "Medicare requirement" to have the oncologist also sign a statement documenting that he was in the office to supervise the chemo. What is this regulation, and where is it located? Does this rule apply only when the supervising physician is different from the ordering physician? We have a process to ensure that the chemotherapy is billed to the supervising physician if the ordering physician is out of the office, so I don't need clarification on physician-supervision requirements per se. Iowa Subscriber Answer: Medicare requires that a physician be present in order to bill for administration of chemotherapy in the office. As you described, the person present may be a colleague of the ordering physician. Billing the chemotherapy under the supervising physician is a clean way to manage the physician-supervision requirements. There is no requirement that a physician document in the medical record his supervision on the day the chemotherapy is administered.

However, chart documentation that points to the presence of a supervising physician will help you reflect compliance with the rule. Anurse documenting the physician coverage can effectively handle this. For example, the nurse may review the labs and notify the supervising physician of any questions or problems. The nurse should document this transaction or can simply state in the chart who is in the clinic supervising that day.