Otolaryngology 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, during the October 7 webinar, “Coding and Documentation for Allergy 2021-2022.”

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 otolaryngologists use, including most allergy tests (95004-95065), Cobuzzi noted.

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 as 95165 (Professional services for the supervision of preparation and provision of antigens for allergen immunotherapy; single or multiple antigens (specify number of doses))

Differentiate Allergy Tests, Allergy Shots

Allergy shots are not diagnostic tests, and the supervision concept for diagnostic testing does not apply. However, allergy tests require either direct or personal supervision in case the patient has an anaphylactic reaction to a test and the physician must perform emergency lifesaving treatment.

Direct supervision is required for such codes as 95004 (Percutaneous tests (scratch, puncture, prick) with allergenic extracts, immediate type reaction, including test interpretation and report, specify number of tests) and 95052 (Photo patch test(s) (specify number of tests)).

On the other hand, you must maintain personal supervision — meaning the physician stays in the room — for codes 95060 (Ophthalmic mucous membrane tests) and 95070 (Inhalation bronchial challenge testing (not including necessary pulmonary function tests), with histamine, methacholine, or similar compounds).

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.”

When it comes to allergy testing and immunotherapy, it’s important to know your state medical board’s regulations on supervision. For instance, some states specifically bar certified medical assistants (CMAs) from performing scratch tests or preparing antigens for immunotherapy. Other states, however, allow CMAs to administer allergy testing.

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