Medicare Transmittal 1456 was effective March 24, 2008. Among some clarifications was the addition of a parenthetical in red below:
"Periodic visits (at least one per month) to the patient during dialysis to ascertain
whether the dialysis is working well and whether the patient is tolerating the
procedure well (physiologically and psychologically)."

Do you interpret this addition to mean that if a physician performs only one visit in a month, that the visit must be in the dialysis unit while the patient is on dialysis in order to bill the one visit MCP?
Does this prohibit him from providing the comprehensive service in the provider's office and billing out the one visit MCP?