On July 1, 2009, CMS placed on display its proposed changes to its Hospital
Outpatient Prospective Payment System rule. Included among those changes
are proposals to alter CMS's physician supervision requirements pertaining to
hospital outpatient services, requirements that have been in flux since last
year. As readers will recall, in CMS's calendar year (CY) 2009 proposed and
final rules, the agency provided what it termed a restatement and clarification
of the requirements for physician supervision of hospital diagnostic and
therapeutic services. (See "Be Careful What You Assume" and "Clarity is
Hard to Find.") In those rules, CMS appeared to reverse long-standing policy
by requiring physician supervision in locations and instances when that
supervision had previously been assumed to be in place. In the 2010 proposed
rule, however, CMS has proposed a somewhat different approach. Ober|Kaler's Thomas Coons explains.
Please see full publication below for more information.