Guideline help

jshattuck

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We perform a procedure that requires, per payor guidelines, DIRECT supervision of a psychiatrist. Some in my clinic think that if we have cash paying patients, this does not apply and can be done how the clinic chooses. I disagree and believe it is best practice to still follow guidelines no matter the patients financial situation. Does anyone have any advice they can give me on if I am correct, and if so where this would be found in documentation to show ones in my clinic.
 
There's a difference between what's required and what's a best practice. You've said that this is a particular payer's requirement, and if that's the case, then it would not apply to patients not covered by that payer (unless of course it also happens to be a legal requirement in the state where your providers are practicing.) But I do agree that it's a best practice to standardize your policies and procedures and treat all of your patients the same way. No only is it just a good idea to offer all patient the same level and quality of care regardless of payer status, but in addition, patients do change from one payer to another and you may sometimes not learn until after the fact that the patient actually may have been covered by a particular payer. So it can potentially create a lot of headaches if your providers are tailoring their procedures to the patient's specific payer.

All that said, though, if direct supervision isn't a legal requirement then I don't think you're going to find any documentation that says your providers have to do this if they elect not to.
 
It is all payors I have found so far, not just one in particular. That is very helpful, thank you.
 
There's probably a good clinical reason why payers want a psychiatrist (an MD) to directly supervise. What are the requirements of the code--meaning, what does the CPT code say you have to do? I would use that say "no, this is what needs to be done." Having worked in risk for a long time, I always think about "what is the worst possible scenario, and how do we prove we were not negligent?" I mean, if someone is acting negligent and with reckless disregard, you're out of luck--but if it's a grey area, how do you stay on the side of "we followed best practices and evidence-based guidelines, and this was just a freak happenstance."
 
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