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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