The general rule for contrast supervision is direct supervision defined as follows:
"the physician (or other supervising practitioner) must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician (or other supervising practitioner) must be present in the room when the procedure is performed." 42 CFR 410.32(b)(3)(ii).
Notice it says "in the office suite and immediately available". There may be other questions about the supervision of the study based on the qualifications of the physician or other professional doing the supervision.
Until COVID hit, that was it, but the regulation was amended to allow alternative means of supervision during COVID:
"Until the later of the end of the calendar year in which the PHE as defined in § 400.200 of this chapter ends or, December 31, 2021, the presence of the physician (or other practitioner) includes virtual presence through audio/video real-time communications technology (excluding audio-only)."
I would get the advice of counsel on this, but I think you have a problem.
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