Practice Management

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  • 1.  Major Changes Made Today to Rules regarding Supervision of Diagnostic Tests

    Posted 04-30-2020 16:11
    CMS issued a new set of interim final rules today in response to the public health emergency. They have made some significant changes to the supervision rules.

    From today's Interim Final Rule at:

    https://www.cms.gov/files/document/covid-medicare-and-medicaid-ifc2.pdf

    See the preable discussion on beginning on page 20. Note the changes to the supervision rules described in the preamble discussion beginning on p. 20. Currently only physicians can supervise diagnostic tests. CMS has amended 42 CFR 410.32 to also allow, during the public health emergency, such supervision to be conducted by a NP, CNS, PA, or CNM.


    CMS has also modified the teaching physician rules regarding supervision of physicians in training interpreting radiology and other diagnostic tests. Here is the new regulatory language:

     

    • 415.180 Teaching setting requirements for the interpretation of diagnostic radiology and other diagnostic tests.
    • General rule. Physician fee schedule payment is made for the interpretation of diagnostic radiology and other diagnostic tests if the interpretation is performed or reviewed by a physician other than a resident. During the Public Health Emergency, as defined in §400.200 of this chapter, for the COVID-19 pandemic, physician fee schedule payment may also be made for the interpretation of diagnostic radiology and other diagnostic tests if the interpretation is performed by a resident when the teaching physician is present through audio/video real-time communications technology

     
    Tom

    Thomas W. Greeson
    703.641.4242
    tgreeson@reedsmith.com

    Reed Smith LLP
    7900 Tysons One Place, Suite 500

    McLean, VA 22102
    703.641.4200
    703.641-4340 Fax
    www.ThomasGreeson.com



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    Thomas Greeson JD, FRBMA
    Partner
    Reed Smith LLP
    Mc Lean VA
    (703) 641-4242
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  • 2.  RE: Major Changes Made Today to Rules regarding Supervision of Diagnostic Tests

    Posted 05-01-2020 11:20
    Thank you Tom!

    Would this change in supervision allow PAs/NPs/CRNAs to monitor contrast injections in an outpatient setting without a physician onsite?

    Thanks,
    Glenn

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    Glenn Kaplan
    VP, Radiology
    Envision Healthcare
    Plantation FL
    (954) 939-6615
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  • 3.  RE: Major Changes Made Today to Rules regarding Supervision of Diagnostic Tests

    Posted 05-01-2020 11:58

    That is correct, although I do not believe it permits these mid-levels to supervise a diagnostic test with contrast in an IDTF setting. The  supervising physician in an IDTF setting must be proficient in the interpretation of the tests performed by the IDTF.

     

    So this change to the supervision rules applies to physician offices and hospital outpatient departments.

     

    Thomas W. Greeson
    703.641.4242
    tgreeson@reedsmith.com

    Reed Smith LLP
    7900 Tysons One Place, Suite 500

    McLean, VA 22102
    703.641.4200
    703.641-4340 Fax
    www.ThomasGreeson.com

     

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