It seems like a couple of different issues are being confused here.
The Medicare supervision rules only apply to the technical component of diagnostic services. You can find the applicable codes in the MPFS RVU files (available at
https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/PFS-Relative-Value-Files.html), denoted with something other than a 09 in the Physician Supervision of Diagnostic Procedures column. You can check the codes you have in mind, but I think you will find that the concept doesn't apply to injection codes, so I don't believe CMS has ever had any supervision requirements for those procedures.
There are two other pertinent questions:
1. Would an RPA/RA would be able to perform the injection under their state license? That's a question to pose to the state entity that licenses those professionals. If it's done in a hospital setting, hospital credentialing would also be a consideration.
2. How would you get paid, or are you prepared to provide those services free of charge? Obviously RPA's and RA's can't bill Medicare for their services, and in general physicians can't bill for services they don't personally perform, unless they fall within the scope of "incident to" office services.
An alternative might be to use a Physician Assistant or Nurse Practitioner who can bill, provided that it falls within the scope of their license in your state. There may be supervision requirements imposed by the state in that case.
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
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Original Message:
Sent: 12-21-2018 11:28
From: Marcel Huber
Subject: RPA RAA 2019 supervision of diagnostic tests
One of our radiologists mentioned that he feels RPAs/RAAs should be able to perform joint injections for pain management under direct supervision in 2019 because they're "diagnostic" in nature since the procedure note includes pre and post injection pain levels that provide "diagnostic" information for management of the patient's pain by the treating provider. I'm not sure this fits the intent of CMS in the federal register where they state "diagnostic tests" and "diagnostic imaging procedures" can be performed under direct supervision. Thoughts on this?
Thanks,
Marcel Huber
Rocky Mountain Radiologists, PC
Ph 303-753-1191
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