Physician Supervision in the Hospital Outpatient Setting - Final 2010 OPPS Rule

CMS has revised or better defined several current policies for the supervision of outpatient services. The goal, per CMS, is “to ensure that hospital outpatient services are appropriately supervised by qualified practitioners while not impeding beneficiary access to these services, and in response to concerns raised by the hospital community.” In 2010, CMS will allow certain non-physician practitioners (NPP) (specifically physician assistants, nurse practitioners, clinical nurse specialists, certified nurse midwives, and licensed social workers) to provide direct supervision for all hospital outpatient therapeutic services that they are authorized to personally perform according to their state scope of practice rules and hospital-granted privileges. 

Under current policy, only physicians may provide the direct supervision of these services. For purposes of on-campus hospital outpatient therapeutic services, CMS is defining direct supervision to mean that the physician or NPP must be present anywhere on the hospital campus and immediately available to furnish assistance and direction throughout the procedure. For services furnished in an off-campus provider-based department, direct supervision would continue to mean that the physician or NPP must be present in the off-campus, provider-based department and immediately available to furnish assistance and direction throughout the procedure. In addition, all hospital outpatient diagnostic services furnished directly or under arrangement, whether provided in the hospital, in a provider-based department, or at a nonhospital location, must follow the MPFS physician supervision requirements for individual tests.

Written by Kim Charland, BA, RHIT, CCS