HCFA recently released a Program Memorandum (B01-28) updating its regulations governing physician supervision of diagnostic tests.
According to coding experts, the memorandum targets diagnostic tests that are performed outside of a hospital setting. These would include services provided in physicians offices and independent diagnostic testing facilities (IDTF) like imaging centers, says Cindy Parman, CPC, CPC-H, co-owner of Coding Strategies Inc., an Atlanta-based firm that supports 1,000 radiologists and 350 multispecialty physicians.
Note: Diagnostic tests conducted on hospital patients are governed by separate guidelines contained in the Code of Federal Regulations.
Supervision Categorized in Three Levels
The Program Memorandum sets forth revised levels of physician supervision required for diagnostic tests payable under the Medicare Physician
Fee Schedule . Section 410.32(b) of the Code of Federal Regulations, as adopted in the Medicare physician fee schedule final rule of Oct. 31, 1997, requires that diagnostic tests covered under 1861(s)(3) of the Social Security Act and payable under the Physician Fee Schedule, with certain exceptions listed in the regulation, have to be performed under the supervision of an individual meeting the definition of a physician (1861(r) of the Social Security Act) to be considered reasonable and necessary and, therefore, covered under Medicare.
This specific notice contains a long list of codes and indicates one of three categories of physician involvement that is necessary during outpatient diagnostic testing, explains Mary Falbo, MBA, CPC, president of Millennium Healthcare Consulting Inc., a national healthcare consulting firm specializing in financial and healthcare management with a focus on physician compliance, coding, billing and reimbursement issues, based in Lansdale, Pa. The regulation defines levels of physician supervision for diagnostic tests as follows:
General Supervision The test is furnished under the physicians overall direction and control, but the physicians physical presence is not required during the procedure. Training of personnel and maintenance of the necessary equipment and supplies are the continuing responsibility of the physician.
Direct Supervision The physician must be present in the office suite and immediately available to furnish assistance and direction throughout the procedure. This level does not require the physician be in the room during a diagnostic test.
Personal Supervision The physician must be in attendance in the room where the procedure is being performed.
In the Program Memorandum, general supervision is indicated with a 1, direct supervision with a 2, and personal supervision with a 3, Falbo notes.
These guidelines will raise questions in a number of areas, Parman says, and are likely to renew debate about what constitutes the immediate availability of the radiologist, as required with direct supervision.
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