Clarity Is Hard to Find: CMS's CY 2009 "Clarification" Regarding Physician Direct Supervision Requirement for Hospital Outpatient Department Services Raises More Questions than it Answers


CMS's CY 2009 final rule for the outpatient prospective payment system

(OPPS) includes a "restatement and clarification of [CMS's] longstanding

OPPS policy" regarding physician supervision of hospital outpatient

department (HOPD) services. Ober|Kaler's Tom Coons and Mark Stanley says that the "clarification" raises more questions than it answers.

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