Oncology & Hematology Coding Alert

Here’s what personal versus direct supervision mean.

For diagnostic imaging services, your freestanding oncology/ hematology center can use physician supervision information in the Medicare Physician Fee Schedule (MPFS) to ensure you stay compliant. Just follow these hints.

Draw the Line Between TC, PC

One of the building blocks of supervision compliance is understanding the difference between the technical component and the professional component of a diagnostic test.

Consider this: In a typical diagnostic imaging scenario, a technician uses diagnostic testing equipment to perform an ordered test on a patient. Then, an interpreting physician reviews the resulting image and provides a written interpretative report as a result of their review of the testing information.

Medicare typically divides codes for diagnostic imaging into components for technical (technician’s salary, cost of equipment and building maintenance, etc.) and professional (the physician’s time, work, expenses, etc.). Each component has a distinct value (fee) reflecting the different resources and effort involved. The technical and professional components of the same code may have different Medicare supervision requirements because the supervision concept doesn’t apply to the professional component the physician performs.

Coding impact: To ensure proper payment for the service rendered when billing is handled by a physician office or freestanding practice, an entity billing only the technical component appends modifier TC (Technical component…) to the diagnostic imaging code. An entity billing only the professional component appends modifier 26 (Professional component) to the code. If an entity provides both the professional and technical components, then it reports the global (complete) service by not appending either TC or 26 to the code.

Unlock Supervision-Level Vocabulary

Another key skill is deciphering Medicare’s supervision level definitions. You need to master three Medicare supervision levels in particular-- general, direct, and personal.

General supervision: “Per Medicare, general supervision ‘means the procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. Under general supervision, the training of the nonphysician personnel who actually performs the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician,’” says Melanie Witt, RN, MA, an independent coding expert based in Guadalupita, New Mexico.

You’ll find the above definition in the Medicare Benefit Policy Manual (MBPM), Chapter 15, Section 80 (www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.pdf). The same section provides the following definitions for direct and personal supervision.

Direct supervision: Direct supervision “in the office setting means the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician must be present in the room when the procedure is performed.”

Personal supervision: “A physician must be in attendance in the room during the performance of the procedure” to qualify as personal supervision.

Audit tip: Documentation should support the required level of supervision. For instance, for procedures requiring personal supervision, the progress note could include a comment by the supervising physician documenting his presence in the room. Alternatively, a procedure room roster of participants, with time in and out recorded for each person, may suffice. Remember, the physician’s documentation must also meet requirements to support his involvement and portion of the service provided.

Decipher MPFS Numerical Indicators

Now that you can identify a code’s technical component and know the definitions of three key supervision levels, it’s time to apply what you know to diagnostic imaging codes on the MPFS.

The MPFS at CMS.gov uses numerical indicators for the supervision levels. So, you need yet another decryption tool before you can determine the supervision level requirement for a given code. The MBPM lists more than a dozen supervision