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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.


KOHLER HealthCare Consulting, Inc. (KHC) has been at the forefront of hospital compliance, documentation, coding, operational issues including outpatient, inpatient and physician education, training and auditing services for over 30 years.


From experience gained working on the inside of hospitals and professional fee practices, health care providers have called on KHC to provide detailed training to their staff, hospital personnel, and medical groups. We’ve been hired to educate hospital front line staff, managers, and HIM, as well as physicians, and facilitate the development of compliance programs to ensure regulatory compliance at every level.


Compliance requires more than the right documentation and the selection of the right codes – it means meeting all technical regulatory requirements. It’s understanding both the Part A and Part B, C and D – for hospitals, professional fee billing, pharmaceutical, or other facilities and suppliers – to get to the right compliance answer. It’s protection against potential repayments.


Whether you need someone to guide you through an assessment of your current regulatory compliance status, an expert witness for litigation against a provider, a one-on-one informational session, or someone to function as an Independent Review Organization, look to KHC for definitive and supportable assistance.


Services Provided:

  • Independent Review Organization (IRO)
  • Independent Compliance Coding
  • Education and Training
  • Resolution of Regulatory Issues
  • Documentation of Services Provided

Approach to Improvements


The philosophical approach toward compliance and operations involves evaluating the details while understanding the global problems and implementing guidance and useful tools that empower our providers to succeed.


Contact us to help

put the pieces together

(410) 461 − 5116


Collaboration + Knowledge = Sustainable Results

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