CMS Proposes Additional Changes to the Outpatient Physician Supervision Requirements

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Over the past two years, CMS has implemented significant "clarifications" of, and changes to, its policies regarding supervision of diagnostic and therapeutic services furnished in hospital outpatient departments or, in some instances, furnished in non-hospital locations under arrangements. As those rules currently stand, for outpatient therapeutic services furnished in an outpatient department located "at the hospital," CMS requires that those services be directly supervised by either physicians or non-physician practitioners (NPPs) acting in accordance with state law, with the physician or NPP being present on the hospital campus and immediately available to furnish assistance and direction through the performance of the procedure. If the service is furnished in an off-campus hospital location, the supervisory personnel must be physically present in the off-campus provider-based department and immediately available to furnish assistance and direction throughout the performance of the procedure. Hospital diagnostic services are subject to similar rules. Ober|Kaler's Thomas W. Coons discusses.

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