You should always insure that your written policies identify the level of supervision required in the Medicare fee schedule for specific tests AND your State regulations on performance so you are consistently in compliance. While Medicare may permit a service under “general supervision” of a physician, your State regulations may require specific certifications to operate the testing equipment. We see this frequently with the technical components for radiation regulations and neuro testing procedures.
That being said, general Medicare regulations require all diagnostic x-ray and other diagnostic tests to be furnished under at least a general level of physician supervision with some tests more restricted and require either direct or personal supervision.
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 perform the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician. (Supervision Indicator 1)
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. (Supervision Indicator 2)
Personal supervision means a physician must be in attendance in the room during the performance of the procedure. (Supervision Indicator 3)
Indicators
- 1 Procedure must be performed under the general supervision of a physician.
- 2 Procedure must be performed under the direct supervision of a physician.
- 3 Procedure must be performed under the personal supervision of a physician.
- 6 Procedure must be performed by a physician or by a physical therapist (PT) who is certified by the American Board of Physical Therapy Specialties (ABPTS) as a qualified electrophysiologic clinical specialist and is permitted to provide the procedure under State law.
- 6a Supervision standards for level 66 apply; in addition, the PT with ABPTS certification may supervise another PT but only the PT with ABPTS certification may bill.
- 7a Supervision standards for level 77 apply; in addition, the PT with ABPTS certification may supervise another PT but only the PT with ABPTS certification may bill.
- 9 Concept does not apply.
- 21 Procedure must be performed by a technician with certification under general supervision of a physician; otherwise must be performed under direct supervision of a physician.
- 22 Procedure may be performed by a technician with on-line real-time contact with physician.
- 66 Procedure must be performed by a physician or by a PT with ABPTS certification and certification in this specific procedure.
- 77 Procedure must be performed by a PT with ABPTS certification or by a PT without certification under direct supervision of a physician, or by a technician with certification under general supervision of a physician.