Wiki Need clarification re: statement made in CMS' TCM Fact Sheet

[Quaker]

Need help with the following question.

The TCM Fact Sheet includes the following statement on page 3:

Supervision
"The required face to face visit must be furnished under a minimum of direct supervision and is subject to applicable State Laws..."

Can anyone explain what this statement means? I understand that there are certain non face to face services that can be delegated to clinical staff by the MD or NPP, however I did not think that the face to face portion of the visit could be delegated. I presumed that either the MD or the NPP who assumes responsiblility for the TCM service would perform the face to face visit. It doesn't seem to make sense that an MD would bill for the TCM service if the NPP performed the face to face visit and plan of care. It was always my understanding that a TCM service is not appropriate for "incident-to" billing but CMS' statement noted above has confused me.

Please help!

 

[Cynthia Hughes]

TCM and incident-to

It is possible that an advanced practice professional such as a physician assistant or nurse practitioner would provide the face-to-face visit within the required time frame and yet the overall TCM service be reported by the physician who is overseeing the entire period of care. I think this point regarding direct supervision is made because of the CMS allowance for provision of the non-face-to-face TCM clinical staff activities provided under general supervision. Clinical staff activities may be performed by advanced practice professionals, nurses, or other qualified clinicians (as allowed by state scope of practice for nursing services) so the differentiation between required levels of supervision was noted.

I hope that helps.
Cindy