Wiki Physicians and other Clinicians: CMS Flexibilities to Fight COVID19 - released 3/30/20

Attached on Page 3 under Workforce - Is this saying that "incident to" can now be billed through video - PA is the Service provider and the Supervising Physician can be the Billing Provider as long as they are available for the PA virtually whether phone or video..


Workforce
• Medicare Physician Supervision requirements: For services requiring direct supervision by the physician or other practitioner, that physician supervision can be provided virtually using real-time audio/video technology.

Please respond with interpretations of this new Flexibility

Thank you ,

Belinda CPC

I don't think they went far enough in their statement. What does "direction supervision" mean when it is virtual? Does that mean the supervising practitioner has to already be hooked up, or does that mean they can be standing by to be called if a problem arises?

I would say they would have to already be hooked up with audio/video, because that is the only way they would be immediately available, just as if it were in the office and you had a problem, you could go to the exam room next door and pull the doctor out of there. If you're not already hooked up, what if you can't get a connection established??

I too am confused as whether this means PA & NP services may be billed incident to even if the physician is not physically present. Since to me, it does not state that clearly, we have been billing NPP services under the NPP.
When they state services requiring direct supervision, I am thinking more along the lines of scope of practice vs incident-to which is really a billing rule.
I would interpret it for services like chemotherapy infusions or radiation therapy, the nurse or tech could be in the building with the physician having an established video connection.
And that's my 2 cents.