Article | March 21, 2022

CMS Physician Supervision for Hospital Outpatient Services- Allowing Hospitals to Bill for Services Provided

Hospitals faced new physician supervision requirements in 2010 and a compliance risk for incident-to services billed in 2009. CMS has increased its focus for what hospitals must assure to bill for outpatient services. Kohler HealthCare Consulting is available to explain the changes, help you internally access your ability to meet these requirements, discuss how to audit your services, and meet the requirements. KHC has developed comprehensive resources and work plans to identify diagnostic procedures and services per the CMS Part B Medicare Physician Fee Schedule (MPFS) crosswalk and how to identify through appropriate documentation, including policies and procedures, and progress notes the presence of the supervisory physician or non-physician practitioner.

Kohler HealthCare Consultants will assist you to:

  • Define physician supervision
  • Apply the right physician supervision rules for each outpatient service area
  • Provide guidance to your management staff to apply requirements
  • Determine how the current changes will impact your business decisions
  • Manage the current physician supervision rules
  • Audit for compliance with all physician supervision rules

Our detailed work plan for your hospital includes:

1.   2009 physician supervision requirements

  • Non-physician practitioners (NPPs)
  • On campus facilities
  • Limitations on enforcement

2.   Changes for 2010 and 2011

  • Non-physician practitioners (NPPs)
  • Qualifications of the practitioner
  • Definition of immediately available

3.   Diagnostic services

  • Under arrangements services

4.   Cardiac rehab, intensive cardiac rehab, and pulmonary rehab

5.   Develop risk assessment tools for your use

6.   Corrective action plans

  • Policies and procedures preparation or revision
  • Physician and auxiliary staff training

7.  Auditing of all years for compliance

8.  Establishing an internal process for remaining compliant with CMS MPFS quarterly updates and CMS interpretation of the outpatient hospital physician supervision rule.

Get a start on this little understood CMS requirement. We have a one-hour educational program to introduce the hospital management team to the issues and concerns.