Physician Supervision and Incident-To Requirements.

Demystify The Supervisory Requirements For Provider-Based Services

The specific requirement for physician supervision is an area of confusion for many healthcare members. The questions that come to mind are— how has CMS changed the supervision requirement over the last several years? Why the physician supervision has recently become such an issue. Can mid-level practitioners satisfy the supervisory requirements? What affirmative steps must hospitals take to ensure compliance? Is this solely a Medicare issue? Can auditors go back in time to verify proper physician supervision? What additional changes are anticipated in the near future? What are the compliance implications? Will this ever become a RAC issue?

To find the answers, join Dr Duane Abbey, Ph.D. in this information-packed 90 minutes session.

Objectives of the session:

• To delineate the various requirements under the Provider-Based Rule (42 CFR §413.65) relating to physician supervision requirements
• To discuss the basic operational processes for provider-based clinics and hospital provider-based clinical activities
• To understand differing requirements for in-hospital, on-campus and off-campus clinics and hospital operations
• To review the supervisory requirements for provider-based services
• To understand how the supervision requirements have morphed over the past several years
• To appreciate both the overt and the subtle changes being made by CMS relative to supervisory requirements for hospital-based operations
• To understand the concept of ‘incident-to’ for both physicians and hospitals
• To discuss the difference between ‘clarifying’ guidance and ‘changed’ guidance
• Appreciate the steps that must be taken relative to documentation for meeting the supervisory requirements
• To discuss possible RAC audit issues for retroactive application
• To work through several case studies

Agenda of the session:

• Review of the Provider-Based Rule (PBR)
  • Development of the PBR
  • 42 CFR §413.65 and Related Entries
  • Rules and Regulations
  • Physician Supervision Concerns
• Compliance Issues for Provider-Based Clinics
  • Meeting Requirements and Conducting Audits
  • Supervision Requirements
  • Location Dependence
    • In-Hospital
    • Out-of-Hospital and On-Campus
    • Off-Campus
• Physician Supervision Requirements
  • April 7, 2000 Federal Register
  • CY2008 - CY2013 Federal Register Discussions
  • Policy ‘Change’ versus ‘Clarification’
  • New Supervisory Statements from CMS
  • Compliance Concerns in Meeting Supervisory Requirements
  • Important Areas – Observation, Infusions, Injections, Radiation Oncology
  • Provider-Based Clinic Challenges
  • Non-Physician Practitioner Involvement
  • Cardiac and Pulmonary Rehabilitation Requirements
  • Establishing Who Is Providing Supervision
• Operational Concerns
  • Documenting Who Is Providing Supervision
  • Keeping Physician/Practitioner Logs
• RAC Audit Concerns
  • Supervisory Requirements Not Met – Recoup Payment
  • Retroactive Application of Policy Changes
• Case Studies
  • Infusion Centers
  • Wound Care Centers
  • Radiation Oncology
  • Provider-Based Clinics

Prerequisites for Participating:  General knowledge of hospitals and various clinic and/or clinical operations.

Who should attend? All personnel involved with provider-based clinic and/or clinical operations, compliance personnel, coding and billing personnel, nursing staff and interested physicians are encouraged to attend.

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