Good morning all,
I have noticed that the outside interpretation reports (professional component) will
sometimes mention in their technique area that the images were taken at our office. Is it ideal that they document the -TC part this way, or is a header with both office addresses in it sufficient?
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Jennifer Nicholson
Compliance Coordinator
Radiology Regional Center
Fort Myers FL
239-936-2316
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Original Message:
Sent: 03-01-2018 11:42
From: Vicki Parikh
Subject: Medicare Contrast Supervision Guidelines
We are seeking legal counsel as well, but like to educate myself as much as possible first! Thanks again for all the great resources and assistance.
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Vicki Parikh
Practice Administrator
Mid-Delaware Imaging
Dover DE
3027349888 x128
Original Message:
Sent: 03-01-2018 08:58
From: David Smith
Subject: Medicare Contrast Supervision Guidelines
The term "in-office ancillary" commonly refers to one type of exception from the Stark Law that otherwise prohibits referrals for Designated Health Services such as imaging if the ordering provider has a financial relationship with the rendering person or entity. The supervision rules we've been talking about in this thread apply to all physician offices, including those attempting to fit into the "in-office ancillary" exception.
If you are trying to fit into the Stark "in-office ancillary exception", the core supervision requirements are the same, but I believe there may be some additional nuances with respect to the relationship between the ordering clinician/group and the physician providing supervision. Probably best to talk to legal counsel about specifics.
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
Original Message:
Sent: 03-01-2018 08:23
From: Vicki Parikh
Subject: Medicare Contrast Supervision Guidelines
Thank you so much! Does anyone know if the physician office rules are the same for an in-office ancillary imaging setting? Or is that a completely different set of supervision rules?
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Vicki Parikh
Practice Administrator
Mid-Delaware Imaging
Dover DE
3027349888 x128
Original Message:
Sent: 02-28-2018 11:40
From: Pam Kassing
Subject: Medicare Contrast Supervision Guidelines
Here are some resources. Medicare requires direct supervision by a physician (not an NP or PA) for "with contrast" studies. This is for both the office and hospital outpatient setting.
Pam
ACR Radiology Coding Source™ March-April 2014. http://archive.acr.org/Advocacy/Economics-Health-Policy/Billing-Coding/Coding-Source-List/2014/Mar-Apr-2014/Supervision-Levels-Revised-for-Contrast-and-Fluoroscope-Guidance-Codes
Supervision Levels Revised for Contrast and Fluoroscopic Guidance Codes
The Centers for Medicare and Medicaid Services corrected the technical component physician supervision levels for contrast procedures and fluoroscopic guidance codes in the Medicare Physician Fee Schedule database. The revisions were implemented on April 7 and are retroactive to Jan. 1, 2014. The procedures with contrast have been corrected to a level "02", defined as "procedure must be performed under the direct supervision of a physician." Fluoroscopic guidance codes have been revised to level "03" defined as "procedure must be performed under the personal supervision of a physician." Use this LINK to refer to the relevant MLN Matters article and more information on the specific codes and supervision corrections.
ACR Radiology Coding Source™ November-December 2008
http://archive.acr.org/~/media/ACR/Documents/PDF/Economics/Coding-Source/2008-Nov-Dec/Physician-Supervision-Requirements.pdf?la=en
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Pam Kassing MPA, RCC, FRBMA
Senior Economic Advisor
American College of Radiology
Reston VA
(800) 227-5463 x4544
Original Message:
Sent: 02-27-2018 14:42
From: Vicki Parikh
Subject: Medicare Contrast Supervision Guidelines
Hi,
Does anyone have the Medicare guidelines pertaining to Physician supervision for CT and MR contrast injections? Can a NP/PA monitor? Does the person monitoring the injection have to be in the MR suite, same floor, or same building? If someone can give me a copy or link to the actual Medicare rule/regulation regarding the monitoring of MR and CT IV contrast administration in both IDTF and Physician Office settings, that would be great.
Thanks!
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Vicki Parikh
Practice Administrator
Mid-Delaware Imaging
Dover DE
3027349888 x128
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