Practice Management

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  • 1.  Another direct supervision of contrast question

    Posted 04-14-2022 15:24

    Hi all,

    We have been operating under the policy, indicated by the MPFS rule for 2022, that remote supervision of contrast is sufficient at least until the end of 2022.  We just received a note from a partner facility that contains a link to an ACR statement (posted in January) that asserts after April 16th, ACR will no allow for remote supervision to occur (statement included below). 

    I assume that this simply coincides with the CMS quarterly determination that a state of Public Health Emergency still exists, and is itself extended on a quarterly basis in lockstep with CMS.  However, I cannot locate another subsequent ACR publication that supersedes this January directive to extend another 3 months.   

    Does anyone have any info on the current status of ACR forbearance regarding this?

    Thanks!

    Craig 



    Direct Supervision For Contrast Studies

    ACR's CT and MR Accreditation Program requirements specify that the supervising physician is responsible for ensuring that a physician is present and immediately available when intravascular contrast material is administered to patients. On March 31, 2020, CMS issued an Interim Final Rule (IFR) that, among other provisions, temporarily modified CMS' direct supervision requirements in certain circumstances. In keeping with CMS' decision to provide "flexibility in direct supervision requirements as needed during this Public Health Emergency (PHE) to reduce exposure risks for the beneficiary or health care provider", the ACR is temporarily relaxing our CT and MR accreditation program requirements related to physician supervision of intravascular contrast material administration. EFFECTIVE IMMEDIATELY, UNTIL April 16, 2022 (extended from prior timeframe of January 16, 2021), FOR PURPOSES OF THE DIRECT SUPERVISION REQUIREMENTS OF ACR'S CT AND MR ACCREDITATION PROGRAM REQUIREMENTS "…the virtual presence of the physician through audio/video real-time communications technology will be allowed during this emergency period when use of such technology is indicated to reduce exposure risks for the beneficiary or health care provider" as long as the administration is done in communication with an immediately available technologist, nurse, or advanced practice provider. ACR will closely monitor the situation and may change this temporary policy as appropriate to address the public health concern. We will notify accredited facilities of any such changes on the CT and MRI accreditation webpages.

    Notwithstanding CMS' and ACR MR & CT Program's temporary relaxation of its requirements related to direct supervision, facilities should consider whether any other applicable statutory, regulatory, licensing or contractual requirements might limit their ability to modify their processes related to supervision. Moreover, facilities intending to allow virtual direct supervision should ensure adequate staff resources and processes are in place to address any on-site emergencies or issues that may arise.



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    Craig Carter
    Chief Operating Officer
    Radiology Associates of North Texas
    Fort Worth
    (817) 321-0313
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  • 2.  RE: Another direct supervision of contrast question

    Posted 04-14-2022 15:38

    The PHE was just extended yesterday, so ACR may not have had a chance to update their document yet.

     

    I wouldn't count on many more extensions, though CMS has indicated that they will give some advance notice.

     

    Dave

     

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  • 3.  RE: Another direct supervision of contrast question

    Posted 04-14-2022 16:03

    Thanks David, I just noted that myself.  I wager we will hear about a new extension from the ACR very soon since they have operated in lockstep with that quarterly HHS PHE determination. 

    HOWEVER, it looks like they have decoupled from the CMS ruling, which will extend until at least the end of 2022.  If that is the case, we may see a situation in a few months where the ACR requires onsite coverage for accreditation and CMS does not.  

    Thanks,

    Craig



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



  • 4.  RE: Another direct supervision of contrast question

    Posted 04-14-2022 16:13
      |   view attached

    I have seen this statement from ACR regarding supervision of accredited ADI units. What is puzzling about ACR's statement is that it provides that direct supervision of Level 2 diagnostic tests through virtual presence through audio/video real-time communications technology would end on the last day of the PHE and not on the last day of the calendar year in which the PHE ends as provided for by CMS at 42 CFR 410.32(b)(3)(ii).

     

    So if the PHE ends in July, will those facilities seeking ACR accreditation be unable to virtually supervise contrast studies until December 31 as Medicare permits?

     

    Thomas W. Greeson

    703.517.0495 (cell)

    tgreeson@reedsmith.com

    Pronouns: He/Him/His

     

    Reed Smith LLP

    7900 Tysons One Place

    Suite 500

    McLean, Virginia 22102-5979

    Office: 703 641 4242

    Cell:     703.517.0495

    Facsimile:   703 641 4340

     

     

     

     






  • 5.  RE: Another direct supervision of contrast question

    Posted 04-14-2022 16:50
    Quick update...we have contacted the ACR accreditation administration and they have indicated that they very likely intend to advance the expiration of their direct supervision ruling to correspond with the very recent PHE determination.  However, they do not plan on a final decision and announcement until next week.  We are making our dissatisfaction regarding this known to them, as it seems a poor policy to not provide this guidance prior to expiration of their previous ruling.

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



  • 6.  RE: Another direct supervision of contrast question

    Posted 04-15-2022 17:01
    Edited by Craig Carter 04-15-2022 17:01
    Another quick update...the ACR contacted us and indicated that they have just extended the remote direct supervision requirements until July.


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