Source of Truth for Physician Supervision Level for Facility/Technical Component

cstarnescstarnes
in COMPLIANCE
I am seeking clarification on how to determine the proper level of physician supervision that is required for given diagnostic services/procedures related to the reporting of the Facility/Technical component.  It has always been my understanding that for Outpt. Diagnostic Services, even on the hospital side), one should use the MPFS Physician Supervision Level Indicator value with its corresponding definition.  Recently it was conveyed to me that the MPFS only applied to Professional billing and not Facility billing.  I am trying to determine if this is correct. An example would be an OP radiology test that has both TC and PC components.  The TC component has a Supervision Level of 3 (personal) in the MPFS.  Based on that, it is my understanding that the physician(radiologist) would have to be physically present with the patient during the test in order for the hospital to bill the service.  I am now being told the physician only has to provide direct supervision and just be immediately available.  Does the Physician Supervision Indicator apply to hospital charge reporting? 

Comments

  • RHirschRHirsch
    As I glance through the table, the global charges all have supervision 09- concept does not apply- and the technical component has the "True" supervision level. 1, 2, 3, etc. So the supervision on the TC has to be right. Do you have an example where the PC has supervision 2 and the TC has 3?

    I'm trying to learn this stuff and this is cool!
  • cstarnescstarnes
    Dr. Hirsch, thank you for your response.  I do not have an example related to your question above because the PC component appears to always be 09.  The Physician Supervision column only applies to the TC component of a service/procedure which is the actual administration of the test/procedure.  The specific example that has led me to question this is related to CPT 74230.  For this RS&I CPT the PC component has an Indicator of 9 since only the physician can provide the interpretation and report.  The TC component has an Indicator of 3 meaning that there must be Personal Supervision in order to report/bill the TC component.  I have always been taught that this applies not just to the Professional billing of this diagnostic test but also to the Hospital/Facility billing of the technical component as well.  My understanding is that Hospitals are to use the MPFS Supervision Level for their Facility billing just as Professional billing. However this has been challenged.  A statement was made that the MPFS is only applicable to Professional billing and has no bearing on Hospital billing/reporting.  It has been recommended that only Direct Supervision for the radiology test under CPT 74230 is required for Hospital reporting.  I am seeking verification that the use of the MPFS is correct even for Hospital billing of diagnostic tests.  This appears to be supported in light of the following from the Federal Register,  

    "We have further defined the requirements for diagnostic services furnished to hospital outpatients, including requirements for physician supervision of diagnostic services, in §§ 410.28 and 410.32 of our regulations. Section 410.28(e) states that Medicare Part B makes payment for diagnostic services furnished at provider-based departments (PBDs) of hospitals ‘‘only when the diagnostic services are furnished under the appropriate level of physician supervision specified by CMS in accordance with the definitions in §§ 410.32(b)(3)(i), (b)(3)(ii), and (b)(3)(iii).’’ In addition, in the April 2000 OPPS final rule with comment period (65 FR 18526), we stated that our model for the requirement was the requirement for physician supervision of diagnostic tests payable under the MPFS that was set forth in the CY 1998 MPFS final rule (62 FR 59048). In 2000, we also explained with respect to the supervision requirements for individual diagnostic tests that we intended to instruct hospitals and fiscal intermediaries to use the MPFS as a guide pending issuance of updated requirements. For diagnostic services not listed in the MPFS, we stated that  fiscal intermediaries, in consultation with their medical directors, would define appropriate supervision levels in order to determine whether claims for these services are reasonable and necessary. Since 2000, we have continued to follow the supervision requirements for individual diagnostic tests as listed in the MPFS Relative Value File. "The file is updated quarterly and is available on the CMS Web site at: n on DSK2BSOYB1PROD with RULES2 60576 Federal Register / Vol. 74, No. 223 / Friday, November 20, 2009 / Rules and Regulations http://www.cms.hhs.gov/PhysicianFeeSched/.

  • RHirschRHirsch
    OK, how did they get to "direct supervision" for 74230? If the global fee 74230 has 9 and 74230-26 (the prof fee only) has 9 and 74230-TC, the technical component. has 3, how in the world do they think that "2" direct supervision applies? That's what has me baffled...
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