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

Baker Donelson
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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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