Hospital Outpatient Physician "Supervision": CMS's Latest Rule Offers Greater Operational Flexibility But Still Exemplifies the Issue's Complexity


  • A new CMS Medicare Rule for Calendar Year 2020 reduces the default level of supervision required for hospital outpatient therapeutic services in all hospitals, from "direct" to "general" supervision.
  • The Rule offers greater operational flexibility to providers. "General supervision" requires that the hospital services be furnished under the supervisory practitioner's overall direction and control, including by telephone or other electronic device.
  • CMS retains the ability to increase the supervision level of an individual hospital outpatient service to a higher level.
  • Violations of physician supervision requirements can lead to reimbursement denials and whistleblower lawsuits.
  • CMS will monitor for any decline in the quality of outpatient therapeutic services provided to Medicare beneficiaries as a result of the new payment policy.
  • CMS expects hospitals, in bylaws and policies, to set the levels of supervision for outpatient services commensurate with the complexity of the services.

Medicare providers often ask themselves — or ask legal counsel — the simple question, "What level of supervision applies here?" The answer is hardly ever simple, and, frustratingly, often leads to more questions. What is the service? Who is providing it? In what setting? Will Medicaid be billed? What federal and state laws may regulate the service or the practitioner? Has a regulator defined supervision, or referenced a level of supervision without a definition?

For clinic and emergency room services — also known as "hospital outpatient therapeutic services"1 — CMS recently finalized its proposal to reduce the required level of supervision from direct to general supervision.

This one rule, limited to one payer and one service, illustrates how complex the supervision rules can be.

This is a brief review of the basic principles.

The most recent development: The 2020 Outpatient Prospective Payment System (OPPS) Final Rule

Starting this January 1, Medicare will require merely general supervision as the default level of supervision for all hospital outpatient therapeutic services in all hospitals, including critical access hospitals (CAHs) and small rural hospitals having 100 or fewer beds.

CMS finalized this significant change in its Calendar Year 2020 OPPS rulemaking, 84 Fed. Reg. at  61142 (Nov. 12, 2019), published in the Federal Register today.2

Medicare currently requires the higher level of direct supervision by physician and certain non-physician practitioners (including clinical psychologists, licensed clinical social workers, physician assistants, nurse practitioners, clinical nurse specialists, or certified nurse-midwives) as the minimum default standard for hospital outpatient therapeutic services — with the exception of services at CAHs and small rural hospitals with fewer than 100 beds. At the latter, the controlling standard has been general rather than direct supervision, due to enforcement instructions and legislative actions in place since 2010. 84 Fed. Reg. at 61360.

The new rule will end this "two-tiered system." Requiring that the "default minimum level of supervision for each hospital outpatient therapeutic service is 'general'" sets a "uniformly enforceable supervision standard for all hospital outpatient therapeutic services." Ibid.

General vs. direct supervision; hospitals gain significant operational flexibility

General supervision requires that the hospital services be furnished under the supervisory practitioner's "overall direction and control", 42 C.F.R. §§ 410.27(a)(1)(iv)(B), 410.32(b)(3)(i).3

Direct supervision requires that a supervising practitioner be "immediately available to furnish assistance and direction throughout the performance of the procedure." 42 C.F.R. § 410.27(a)(1)(iv)(A).

Neither requires that the supervisory practitioner be in the room during the service. Yet CMS has in the past distinguished general from direct supervision by requiring an element of physical presence for the latter. (See, e.g., 75 Fed. Reg. at 71800, 72008 (Nov. 24, 2010).) The direct supervision standard requires immediate availability to furnish assistance and direction throughout the performance of the procedure, and would not be met if a supervisory practitioner was performing another procedure or service that he or she could not interrupt. (See MBPM, Ch. 6, § 20.5.2.) CMS's 2020 Final Rule recognizes that requiring direct supervision "places an additional burden on providers." 84 Fed. Reg. at 61360.

This new Rule, by reducing the default supervision standard to general, gives hospitals significantly more operational flexibility. Ibid. General supervision has been "historically interpreted" to allow for modes of supervision other than in-person, including availability by telephone or other electronic device. 74 Fed. Reg. at 60316, 60583 (Nov. 20, 2009); 75 Fed. Reg. at 72008. CMS in this Final Rule noted that general supervision means that "the medical personnel performing the procedure are being monitored and receiving guidance from a qualified physician even if the physician is not physically present." 84 Fed. Reg. at 61362.

Some details: A specific service may still have specific supervision requirements

Although the new Calendar Year 2020 Rule will require general supervision as the default level of supervision, CMS may choose to require direct or even personal supervision for particular services. Id. at 61490. (The current, pre-2020, rule takes a similar approach by allowing CMS to assign general or personal supervision to particular services even though the default is direct supervision. 42 C.F.R. § 410.27(a)(1)(iv)(B).)

Personal supervision requires the supervising practitioner to be in "attendance in the room during the performance of the procedure." 42 C.F.R. §§ 410.27(a)(1)(iv)(B), 410.32(b)(3)(iii).

CMS has not yet designated any procedures as requiring this highest level of supervision but has assigned general supervision to some services.4 And even under the new Rule, CMS will continue to require direct supervision for some services. See 84 Fed. Reg. at 61490. E.g.,

  • Certain nonsurgical extended duration therapeutic services (NSETDS) require a minimum of direct supervision during the initiation of the services followed by general supervision at the discretion of the supervising practitioner. 42 C.F.R. § 410.27(a)(1)(iv)(E); MBPM, Ch. 6, § 20.7. (NSETDS are not primarily surgical in nature, can last a significant period of time, have a substantial monitoring component usually performed by auxiliary personnel, and have a low risk of requiring the supervisory practitioner's immediate availability after the initiation of the service. Ibid.)
  • Pulmonary and cardiac rehabilitation services must still be directly supervised, and only by physicians. (Supervision for these services must be by a doctor of medicine or osteopathy, 42 C.F.R. § 410.27(a)(1)(iv)(D), while Medicare outpatient hospital therapeutic services generally may be supervised by a physician or certain non-physician practitioners.)

CMS reasoned in the 2020 OPPS Rulemaking that providers can always decide to set a higher level themselves, and other laws and regulations indeed already subject some services to other levels of supervision. Hospitals, under this Final Rule, can still choose to provide direct or personal supervision for outpatient services "when the physicians administering the medical procedures decide that it is appropriate to do so." 84 Fed. Reg. at 61360, 61362. And personal supervision may be required by a hospital's bylaws, credentialing procedures, and policies if "the complexity of the service" warrants it. 74 Fed. Reg. at 60584.

For example, some public comments cited in the rulemaking were concerned that a higher level of supervision might be warranted for radiation therapy, hyperbaric oxygen treatments, and wound care services — all highly skilled services that might have rare but serious complications. 84 Fed. Reg. at 61362. CMS replied that, as for any hospital service, "Providers have the flexibility to establish what they believe is the appropriate level of physician supervision for these procedures, which may well be higher than the requirements for general supervision." Ibid.

CMS also noted that providers must adhere to conditions of participation, federal and state regulations for the services, and state standards for scope of practice for medical personnel who provide these services, and that the "combination of providers' desire to ensure the safety of their patients and the regulations governing these procedures . . . should ensure that these procedures will be appropriately supervised . . . whether the default level of physician supervision is direct supervision or general supervision." Ibid. CMS accordingly declined to require a higher supervision level in this rulemaking while acknowledging the variety of other laws that can always be at play.

CMS has revised a decades-old payment standard; hospitals should diligently strive to understand and comply with the New Rule

The transition from direct to general supervision is likely a welcome one for hospitals, but it is a significant departure for CMS, which had rejected general supervision as the minimum standard for hospital outpatient services when commenters suggested it in the past. See, e.g., 74 Fed. Reg. at 60583-84 (2009) and 75 Fed. Reg. at 72008 (2010).

Hospitals must, accordingly, be careful to understand and comply with CMS's new expectations.

Violations of these physician supervision requirements can lead to reimbursement denials and whistleblower lawsuits (whether meritorious or not).

The supervision standards, however, have not always been consistently construed or applied. Medicare adopted the direct supervision requirement in 2000, and CMS initially observed, "We assume the physician supervision requirement is met on hospital premises because staff physicians would always be nearby within the hospital." 65 Fed. Reg. at 18434, 18525 (Apr. 7, 2000).

But CMS issued a "clarification" and "restated the existing policy" eight years later, because

"some stakeholders may have misunderstood our use of the term 'assume' . . . believing that our statement meant that we do not require any supervision . . . or that we only require general supervision for those services. This is not the case. It has been our expectation that hospital outpatient therapeutic services are provided under the direct supervision of physicians in the hospital and in all provider-based departments . . . both on-campus and off-campus departments of the hospital." 73 Fed. Reg. at 68502, 68702-03 (Nov. 18, 2008).

CMS thus has administratively moved from seemingly "assuming" physician supervision, to specifically requiring direct supervision, to now only requiring general supervision — all as deemed consistent with the statutory requirement that hospital outpatient services be provided "incident to physicians' services." Social Security Act § 1861(s)(2)(B) (codified at 42 U.S.C. 1395x(s)(2)(B)).

The government regulator charged with implementing and enforcing payment requirements has the leeway to learn from experience and further interpret the meaning of statutes and regulations.

Providers are often not that lucky.

The meaning of direct supervision in particular has not always been crystal clear, and CMS, lacking an easy way to monitor the standard, has essentially left it up to whistleblowers to raise "any concerns about patient safety due to inappropriate supervision."5 This was rarely the best context for resolving disputes about the standard's meaning. Plaintiffs in False Claims Act cases easily misinterpreted direct supervision to require a level of physician presence that is more akin to personal rather than direct supervision. It seems reasonable to hope that CMS's Final rule implementing a lower level of general supervision will reduce the opportunity for litigation on this issue.

This does not diminish the continuing importance of 42 C.F.R. § 410.27 for hospitals seeking payment under Medicare Part B for outpatient services. This Rule contains conditions of payment (i.e., "Medicare Part B pays . . . if"). Failure to comply may lead to a Medicare payment denial. Fortunately, hospitals should find it easier to meet the payment standard established under the new Rule.

Some other supervision requirements are merely conditions of participation, which may not "cause payment to be denied for that individual service" (84 Fed. Reg. at 61360) (e.g., Medicare hospital patients must be under the care of a physician (42 C.F.R. § 482.12(c)(4)), see ibid.). They too are of paramount importance in complementing the supervision requirement set under this payment rule. CMS reminds hospitals that consistent violations of conditions-of-participation supervision requirements can lead to provider corrective action plans and, ultimately, termination from Medicare participation if deficiencies are not cured. Ibid.

CMS also commits to monitor for any decline in the quality of outpatient therapeutic services provided to Medicare beneficiaries as a result of the new payment policy (84 Fed. Reg. at 61361). Hospitals should keep this in mind as well, when reviewing or setting the appropriate supervision standards for particular outpatient hospital services in provider credentials and hospital bylaws and policies.

1 Medicare Benefit Policy Manual (MBPM), Ch. 6, § 20.5.2.

2 Department of Health and Human Services, Centers for Medicare & Medicaid Services, "Medicare Program: Changes to Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Revisions of Organ Procurement Organizations Conditions of Coverage; Prior Authorization Process and Requirements for Certain Covered Outpatient Department Services; Potential Changes to the Laboratory Date of Service Policy; Changes to Grandfathered Children's Hospitals-Within-Hospitals; Notice of Closure of Two Teaching Hospitals and Opportunity to Apply for Available Slots." Available here.

3 Note that all citations to 42 C.F.R. § 410.27 are to the current version of the regulation (pre-2020).

4 CMS "Hospital Outpatient Therapeutic Services That Have Been Evaluated for a Change in Supervision Level" (March 10, 2015), available here. The agency retains its ability to consider increasing the supervision level of an individual hospital outpatient service to a level more intensive than general supervision through notice and comment rulemaking, and continues to have the Hospital Outpatient Payment Panel provide advice on the appropriate supervision levels for hospital outpatient therapeutic services. 84 Fed. Reg. at 61360-61.

5 Medicare Payment Advisory Commission Report, p. 6, Physician Supervision Requirements in Critical Access Hospitals and Small Rural Hospitals (Dec. 2017), available here.

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.

© Katten Muchin Rosenman LLP | Attorney Advertising

Written by:

Katten Muchin Rosenman LLP

Katten Muchin Rosenman LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.