Practice Management

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  • 1.  Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-23-2023 20:41

    I recently became the Beneficiary Member for WPS's Carrier Advisory Committee for J5 - which covers Iowa, Missouri, Nebraska, and Kansas.  This means I am an official member of the J5 Part B CAC.  Earlier today the Carrier Medical Director shared a CMS publication with the committee he feels is particularly relevant to stakeholders.  This document, which is publicly available, seems to describe the impact of the government's ending of the Public Health Emergency (PHE) will have on the waivers and flexibilities enacted during the emergency. 

    Here is a link to the document.  If you look down the page a bit, you'll see a link titled "Physicians and Other Clinicians."  The date on that document is 2/22/2023.  So, it should be pretty current.  What caught my eye, and why I am posting it here, is what I read on page 11 under the section titled Workforce.  CMS seems to be addressing the Direct Supervision rules (I think) allowing a virtual presence in many cases.  I believe this is what allowed for the remote supervision of contrast injections. It appears, if I am reading this guidance correctly, that this waiver/flexibility will end at the end of the year.  I copied this section below verbatim.  

    Admittedly, since I retired pre-PHE, I've paid little attention to this issue.  Perhaps this is not news.  Perhaps other rules/regulations have changed that will continue to allow remote supervision of contrast injections. However, in the event that neither is the case, I wanted to post this information here as soon as possible. 

    If this is old news, just disregard.  

    Mike Bohl

    ------------------------------Page 11-------------------------------

    • Medicare Physician Supervision Requirements: CMS has temporarily modified the regulatory definition of direct supervision, which requires the supervising physician or 
    practitioner to be "immediately available" to furnish assistance and direction during the service, to include "virtual presence" of the supervising clinician through the use of realtime audio and video technology. This flexibility is currently set to return to pre-PHE rules at the end of the calendar year that the PHE ends



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    Michael Bohl FRBMA
    Retired
    Radiology Group, PC, SC
    Bettendorf IA
    (563) 484-0488
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  • 2.  RE: Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-24-2023 09:18

    Thank you! I had read that it would be ending, but it really didn't say when.  All good things come to an end I guess.  Happy Friday.



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    Mindy Smith BMSC-CCP, FDCPA
    Billing Manager
    Management Data Systems, Inc.
    Lake Charles
    (337) 437-7681
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  • 3.  RE: Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-24-2023 10:36

    Mike,

    Thanks for posting this.  We were aware of this provision ending since thte PHE will be ending soon.  This was a provision inthe MPFS Proposed Rule that RBMA and others encouraged CMS to extend beyond the termination fo the PHE.  

    Glad you are keeping in touch thorugh the CAC.

    Bob Still



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    Robert Still FRBMA
    Executive Director
    Radiology Business Management Association (RBMA)
    Fairfax VA
    (703) 621-3363
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  • 4.  RE: Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-24-2023 10:59

    Hey Mike,

    I believe the supervision rules were temporarily put in place during COVID and were extended for another year during the last rulemaking cycle.  However, I haven't been watching it that closely since I am retired too.  Your service to the radiology community on health policy continues to be unwavering.  A true testimony to why you are a FRBMA.

    Hope all is well.

    Pam



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    Pam Kassing, MPA, FRBMA
    Cornville, AZ
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  • 5.  RE: Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-24-2023 11:40

    Pam,

    Thanks.  I included several disclaimers that there could be other regulatory changes that extended the contrast supervision rule that I am unaware of since I'm not paying as much attention these past few years.  I just wanted to get this out to restart this discussion in case work needs to be done.  I'll let the experts take it from here.

    MB

     






  • 6.  RE: Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-24-2023 13:00
    Hi Pam, 

    And I was thinking they had been extended through CY 2024 in the 2023 Consolidated Appropriations Act.

    Sent from my iPhone





  • 7.  RE: Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-24-2023 15:31

    Virtual real-time supervision of Level 2 diagnostic tests was not among the flexibilities extended by the 2023 Consolidated Appropriations Act, unfortunately.

     

    CMS has left open the possibility of making the rule permanent as part of its CY 2024 MPFS rulemaking. I hope we see them invite stakeholders to comment on whether to make Level 2 tests virtual supervision permanent when they issue their proposed rule this summer.

     






  • 8.  RE: Remote Contrast Supervision Ending At The End Of The Year?

    Posted 02-24-2023 16:41

    I knew you would know, Tom! Thank you!

     

    Barbara F. Rubel MBA, FRBMA

    Senior VP, Marketing & Client Services

    Immediate Past President, FRBMA

     

    brubel@msnllc.com

    904-657-2038 (Office) | 770-823-3597 (Cell)
    MSNLLC.com