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

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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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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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