Keith and Donna, my interpretation of what CMS has proposed is to permanently permit mid-levels to supervise diagnostic tests. The proposal to permit the use of audio or other electronic presence to supervise tests that require direct supervision runs to the end of the public health emergency or until Dec. 31, 2021.
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Thomas W Greeson
Reed Smith LLP
(703) 517-0495
tgreeson@reedsmith.com------------------------------
Original Message:
Sent: 08-04-2020 16:21
From: Keith Chew
Subject: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS
Tom – In my thus far quick review there are a couple of things that cause me to stop and think. Yes it looks like the E&M code changes may go into effect, but they don't say that , only clarifying the level of service that some high end activities will qualify for upon submission – ESRD etc.
But the combination of two areas makes me stop and think
- The fact that NPPs may be allowed to provide supervision for diagnostic tests
- The direct supervision of diagnostic tests may be done via Interactive Telecommunications
These two changes could dramatically alter the offering of radiology exams that require direct supervision. Am I seeing these suggested changes correctly?
Keith E. Chew, MHA, CMPE, FRBMA
Principal – Consulting with Integrity
18 Hawks Nest Chatham, IL 62629
217-971-5293 Direct
Original Message:
Sent: 8/4/2020 11:14:00 AM
From: Thomas Greeson
Subject: RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS
Original Message:
Sent: 8/4/2020 10:23:00 AM
From: Parke Keith
Subject: RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS
Tom,
Thanks for the update ... It appears our facilities are awaiting the storm, but hoping for another delay.
Also, I was not able to make your link work.
This was the link from Melody:
Parke Keith
Radiology of Huntsville
256.539.0457 Office
pkeith@radhunt.com
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Original Message:
Sent: 8/3/2020 9:59:00 PM
From: Thomas Greeson
Subject: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS
Oddly, there appears to be no discussion of the requirement for physicians who order advanced imaging to use clinical decision support mechanisms to consult appropriate use criteria. As you all know, this year is an education and testing year. The expectation had been that the MPFS rule would include an announcement as to whether CMS was going to require such consultation to be mandatory in 2021 or issue a delay.
https://www.cms.gov/files/document/cms-1734-p-pdf.pdf
There must be some other vehicle where CMS will announce the fate of AUC/CDS for 2021.
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Thomas W Greeson
Reed Smith LLP
(703) 517-0495
tgreeson@reedsmith.com
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