Ophthalmology and Optometry Coding Alert

Diagnostic test supervision differs from incident-to supervision.

You’ve memorized the supervision rules for incident-to services, so you should be all set when determining the supervision requirements for diagnostic testing as well, right? Not so fast. Although the two sets of supervision rules have some similarities, there are also differences that you must know to stay on the right side of the compliance rules.

That was the word from Barbara J. Cobuzzi, MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, CMCS, of CRN Healthcare in Tinton Falls, New Jersey, who shared the information during an October 7 webinar.

Get to know some of the most important supervision rules so you aren’t leaving your reimbursement and compliance to chance.

Know the Range of Supervision Options

The supervision requirements for diagnostic testing apply to a wide variety of codes that ophthalmologists use. Diagnostic testing supervision may require one of three levels of supervision: general, direct, or personal supervision, she said. This differs from the incident to guidelines, which require direct supervision. To get a handle on the details of each supervision level, check out the following breakdown that Cobuzzi provided:

• General supervision: The procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required.
• Direct supervision: The physician must be present in the office suite and immediately available to furnish assistance and direction throughout the procedure’s performance. The physician does not have to be present in the room where the service or procedure is performed.
• Personal supervision: The physician must be in the room during the procedure’s performance.

How to Pinpoint Supervision Levels

You can find the supervision levels for any particular code by reviewing the Medicare Physician Fee Schedule. You’ll see numbers assigned to each code’s supervision level, as follows:

• 1: Codes requiring general supervision only
• 2: Codes requiring direct supervision
• 3: Codes requiring personal supervision
• 9: Codes for which the supervision concept does not apply (such is the case for codes like 92025, Computerized corneal topography, unilateral or bilateral, with interpre­tation and report)

You should always confirm which supervision level is assigned to your service before performing it, and make sure you understand that in some cases, the supervision level is different when you append a modifier, such as TC (Technical component) to the code.

Keep State Scope of Practice Rules in Mind

“The physician supervision guidelines apply to Medicare carriers as long as the state’s scope of practice laws or regulations permit nonphysician practitioners (NPPs) to perform these duties,” Cobuzzi said. “For high-level NPPs — physician assistants, nurse practitioners, and clinical nurse specialists, among others — only general supervision is required unless state law rules otherwise.”

In addition, you should keep checking every year, particularly when the calendar turns, to ensure you’re on the right side of the rules.

“The rules can change,” Cobuzzi said. Therefore, you should check the laws in your state to determine who can administer diagnostic tests and who must be supervising.