Practice Management

Hello all,

On July 13th, CMS released the 2022 Medicare Physician Fee Schedule proposed rule.  Within this document, it continues the previous relaxation of direct physician supervision within certain clinical settings (set out originally last year at the start of the pandemic).  Additionally, CMS is seeking comment on whether this flexibility should potentially be made permanent, meaning that the agency could permanently revise the definition of "direct supervision" at § 410.32(b)(3)(ii) to include the supervising physician or practitioner's immediate availability through virtual presence via real-time, interactive audio/video communications technology.

Does anyone have a clear understanding regarding whether this relaxation of requirement of direct supervision relates to radiologist supervision at facilities classified as  Independent Diagnostic Testing Facilities?

Thanks!

Craig Carter
Chief Operating Officer
Radiology Associates of North Texas
ccarter@radntx.com

------------------------------
Craig Carter
Chief Operating Officer
Radiology Associates of North Texas
Fort Worth TX
(817) 321-0313
------------------------------

Original Message:
Sent: 8/5/2021 11:31:00 AM
From: Craig Carter
Subject: IDTFs, Covid and direct Radiologist supervision

Hello all,

On July 13th, CMS released the 2022 Medicare Physician Fee Schedule proposed rule.  Within this document, it continues the previous relaxation of direct physician supervision within certain clinical settings (set out originally last year at the start of the pandemic).  Additionally, CMS is seeking comment on whether this flexibility should potentially be made permanent, meaning that the agency could permanently revise the definition of "direct supervision" at § 410.32(b)(3)(ii) to include the supervising physician or practitioner's immediate availability through virtual presence via real-time, interactive audio/video communications technology.

Does anyone have a clear understanding regarding whether this relaxation of requirement of direct supervision relates to radiologist supervision at facilities classified as  Independent Diagnostic Testing Facilities?

Thanks!

Craig Carter
Chief Operating Officer
Radiology Associates of North Texas
ccarter@radntx.com

------------------------------
Craig Carter
Chief Operating Officer
Radiology Associates of North Texas
Fort Worth TX
(817) 321-0313
------------------------------

Thanks for your quick reply!

Craig

------------------------------
Craig Carter
Chief Operating Officer
Radiology Associates of North Texas
Fort Worth TX
(817) 321-0313
------------------------------

Original Message:
Sent: 08-05-2021 13:50
From: Thomas Greeson
Subject: IDTFs, Covid and direct Radiologist supervision

This is an excellent question. My take on this is that the use of audio/video communications technologies may be used in an IDTF setting so long as the supervising physician meets the "proficiency" requirements of 42 CFR 410.33.

Thomas W. Greeson

Reed Smith LLP

tgreeson@reedsmith.com

(703) 571-0495 (cell) 

 

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Original Message:
Sent: 8/5/2021 11:31:00 AM
From: Craig Carter
Subject: IDTFs, Covid and direct Radiologist supervision

Hello all,

On July 13th, CMS released the 2022 Medicare Physician Fee Schedule proposed rule.  Within this document, it continues the previous relaxation of direct physician supervision within certain clinical settings (set out originally last year at the start of the pandemic).  Additionally, CMS is seeking comment on whether this flexibility should potentially be made permanent, meaning that the agency could permanently revise the definition of "direct supervision" at § 410.32(b)(3)(ii) to include the supervising physician or practitioner's immediate availability through virtual presence via real-time, interactive audio/video communications technology.

Does anyone have a clear understanding regarding whether this relaxation of requirement of direct supervision relates to radiologist supervision at facilities classified as  Independent Diagnostic Testing Facilities?

Thanks!

Craig Carter
Chief Operating Officer
Radiology Associates of North Texas
ccarter@radntx.com

------------------------------
Craig Carter
Chief Operating Officer
Radiology Associates of North Texas
Fort Worth TX
(817) 321-0313
------------------------------