Pulmonology Coding Alert

Breathe Easy With New Physician Supervision Levels for Testing

In Program Memorandum B-01-28 dated April 19, 2001, Medicare announced a revision of its definitions of physician supervision of diagnostic tests. To receive maximum reimbursement, pulmonologists and coders need to be aware of the three levels general, direct and personal and their application to pulmonology diagnostic procedures as specified by HCFA. These new definitions will go into effect on July 1, 2001.

HCFA explained that for these tests to be considered reasonable and necessary, and therefore covered under Medicare, they have to be performed under the supervision of an individual meeting the definition of a physician as defined by the Social Security Act and adapted in the Medicare physician fee schedule final rule of Oct. 31, 1997. To clarify the meaning of supervision, HCFA has revised the definition of the level of the involvement of the physician to include the following three:

General Supervision The diagnostic procedure is performed under the physicians overall direction, but his presence is not required during the actual performance of the test, although he should be available by phone or beeper. He is, however,responsible for training the nonphysician professional who conducts the test as well as for the continued maintenance of the equipment and supplies needed. For the pulmonologist, proceduressuch as spirometry; measurement of breathing capacity, thoracic gas volume, or expired gas collection; determination of airway closing volume or resistance to air flow; and pulmonary stress testing fall under this level of supervision.

Direct Supervision The physician must be present in the office area and be immediately available to offer guidance and direction if either is needed during the performance of the diagnostic test. His presence, however, is not required in the room during the test. For the pulmonologist, this category involves such diagnostic tests as bronchospasm evaluation in response to CO2 or hypoxia, or spirometric evaluation requiring the use of bronchodilators, antigens, or methacholine.

Personal Supervision The physician is required to be in the room during the performance of the procedure. Note: According to the list of procedures and their codes provided by Medicare, none of the diagnostic tests performed by the pulmonologist fall in this category.

Most of the procedures in the general category require the use of a machine only to provide a printout, which is then evaluated by the supervising pulmonologist to arrive at a diagnosis. These tests are not so specialized or invasive that they require the administration of drugs or direct monitoring by a pulmonologist.

Thus, for example, a 45-year-old smoker complaining of shortness of breath, difficulty in breathing, and a cough is referred by her family physician to a pulmonologist. When she arrives for her initial visit, the physician performs a spirometry to establish her [...]
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