Practice Management

In both settings, it depends on the level of supervision.  General supervision for advanced diagnostic imaging must be a radiologist. In a HOPD and an orthopedic office, all advanced diagnostic imaging facilities must be accredited to provide services to Medicare beneficiaries. Every accrediting organization requires the general supervising physician to be a radiologist.

For direct supervision, the Medicare transmittal for the HOPPS supervision provides this guidance. "The supervisory physician must have, within his or her State scope of practice and hospital-granted privileges, the knowledge, skills, ability, and privileges to perform the service or procedure. Specially trained ancillary staff and technicians are the primary operators of some specialized diagnostic testing equipment, and while in such cases CMS does not expect the supervisory physician to operate this equipment instead of a technician, the physician that supervises the provision of the diagnostic service must be knowledgeable about the test and clinically appropriate to furnish the test."

For direct supervision in the orthopedic office, any fully licensed physician, or until the end of the public health emergency, a non-physician practitioner can supervise the diagnostic test.

The CY 2021 MPFS rule would extend the authority to NPPs permanently.

Thomas W. Greeson

703.517.0495 (cell)

tgreeson@reedsmith.com

Reed Smith LLP

7900 Tysons One Place

Suite 500

McLean, Virginia 22102-5979

Telephone: 703 641 4200

Facsimile:   703 641 4340

It depends on if you are an IDTF or a physician practice location. Which are your facilties?