Mr. Greeson -
I do understand that virtual supervision for Level 2 is extended for Physician Office and IDTF.
In the case of off campus Hospital Outpatient Department, can a CRNP cover contrast if the supervising physician is not on site and available to intervene? My understanding from Benefits Policy Manual, Chapter 6, Section 20.4.4 is that in hospital setting, allowing NPP without physician supervision is only if the NPP personally performs the diagnostic test. If they are not performing the CT/MR test, it would not be allowed. Am I interpreting the requirements correctly?
Thanks
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Barbara Mulik
Coding Compliance Coordinator
Medical Imaging of Lehigh Valley, PC
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Original Message:
Sent: 11-30-2023 10:56
From: Thomas Greeson
Subject: Virtual (Indirect) Supervision - CMS Final Ruling
The ability to supervise virtually had been set to end on December 31, 2023, but in the 2024 MPFS final rule, CMS extended that date until December 31, 2024.
Beginning January 1, 42 CFR 410.32(b)(3)(ii) will read as follows:
(ii) Direct supervision in the office setting means the physician (or other supervising practitioner) must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician (or other supervising practitioner) must be present in the room when the procedure is performed. Through December 31, 2024, the presence of the physician (or other practitioner) includes virtual presence through audio/video real-time communications technology (excluding audio-
only).
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This is not intended to be self-serving, but make sure you talk to your legal counsel about the nuances of the rule and what is expected with virtual direct supervision of Level 2 tests with contrast. The rule applies to both physician offices and IDTFs.
Thomas W. Greeson
Partner
Life Sciences Health Industry Group
He/Him/His
tgreeson@reedsmith.com
D: +1 703.641.4242
M: +1 703.517.0495
Reed Smith LLP
7900 Tysons One Place
Suite 500
McLean, VA 22102-5979
T: +1 703 641 4200
F: +1 703 641 4340
reedsmith.com
Original Message:
Sent: 11/30/2023 10:48:00 AM
From: Sheila Witous
Subject: RE: Virtual (Indirect) Supervision - CMS Final Ruling
I saw this also but cannot find anything. Specifically, does this apply to an IDTF?
Thank you!
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Original Message:
Sent: 11/30/2023 10:40:00 AM
From: Kelsey Mascarel
Subject: Virtual (Indirect) Supervision - CMS Final Ruling
I received notice via RBMA News that CMS Extended Virtual Supervision through December of 2024. In all articles and transmittals from the CMS, I have not found where they directly address this in a Radiology setting concerning direct / indirect access to a Physician during contrast administration.
I am seeking guidance and confirmation that this was approved. Please assist me in finding the Final Rule from CMS.
Thank you for your support!
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Kelsey Mascarel
University Diagnostic Institute Winter Park
Winter Park FL
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