This is confusing to the max...
Previously, an MD must be present or proximate to the patient when injecting and observing patients who require contrast.
This interpretation goes against years of mandated present/proximate attendance by an MD.
Sounds foolish if prior GAD injections mandated rules for
patient safety.
Perhaps foolishly we could also interpret this to mean that an 'attending' MD could be connected via two-way video/audio to 20 concurrent injections as long as he could 'observe' the patient(s) during the entire process.
In my opinion (having been saved from probable death by an qualified EMT I would much rather have this EMT professional at my side (or proximate to it) to observe any negative reaction and have his PERSONAL crash kit at the ready.
We've never had a severe reaction to GAD in 27 years of business.
With the requirement for an MD to be proximate/present in case of a bad or life-threatening reaction to contrast media what do we do?
We would call 911 and the local fire department/ambulance crew will be dispatched and a qualified EMT will arrive to ensure that the patient is attended to.
And remember that EMT's see trauma EVERY DAY and most MD's do not by comparison. So who is/could be most qualified?
And don't forget that our imaging technicians are trained in observing/treating patients - at least to a reasonable degree - to observe any negative reaction and take immediate steps to ensure the patient's safety;.
Where do we draw the line between necessity and practicality?
------------------------------
William Kisse
COO
Washington Open MRI, Inc.
Rockville, MD
bill@womri.com(301) 424-4888
https://www.linkedin.com/in/billkisse/------------------------------
Original Message:
Sent: 05-27-2020 13:01
From: Thomas Greeson
Subject: Contrast Coverage during COVID-19
In early April, in response to the COVID-19 public health emergency, CMS published an interim final rule that, among other changes, amended the supervision rules for diagnostic tests to permit those physicians who perform direct supervision of contrast studies to not have to be physically present.
Specifically, CMS stated:
"For the reasons discussed above, on an interim basis for the duration of the PHE for the COVID- 19 pandemic, we are altering the definition of direct supervision at § 410.32(b)(3)(ii), to state that necessary presence of the physician for direct supervision includes virtual presence through audio/video real-time communications technology when use of such technology is indicated to reduce exposure risks for the beneficiary or health care provider. We are revising § 410.32(b)(3)(ii) to include, during a PHE, as defined in § 400.200 of this chapter, the presence of the physician includes virtual presence through audio/video real-time communications technology when use of such technology is indicated to reduce exposure risks for the beneficiary or health care provider."
Thomas W. Greeson
703.641.4242
tgreeson@reedsmith.com
Reed Smith LLP
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McLean, VA 22102
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