Radiology Coding Alert

Reader Question:

Physician Supervision Rules

Question: A few months ago, CMS (which was then called HCFA) issued Program Memorandum B-01-28 explaining its requirements for physician supervision of diagnostic tests. Do these apply to hospital-based radiologists, those practicing in an office setting, or both?

Virginia Subscriber
 
Answer: The first section of PM B-01-28 explicitly states that the rules apply to the office setting. Although it doesn't address hospital services, the Oct. 31, 1997, issue of the Federal Register does. This is where the supervision guidelines first appeared. In that document it states: "The coverage of diagnostic procedures furnished to hospital patients is addressed in other regulations and is not affected by this clarification." Therefore, radiology coders should apply the new physician supervision rules only to the office setting.
 
CMS defers to hospital policy and JCAHO standards for ordering diagnostic tests in the hospital setting.