The technical component of diagnostic tests for a Medicare beneficiary who is not a hospital inpatient or outpatient (generally services performed in an office setting or Independent Diagnostic Testing Facility (IDTF)) must be performed under the appropriate level of physician supervision.
Medicare requires that “diagnostic tests covered under Section 1861(s)(3) of the Social Security Act and payable under the physician fee schedule have to be performed under the supervision of an individual meeting the definition of a physician.” The regulation defines these levels of physician supervision for diagnostic tests as follows:
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 non-physician personnel who actually performs the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician.
Direct supervision – In the office setting, this 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 the physician must be present in the room when the procedure is performed.
Personal supervision – Means a physician must be in attendance in the room during the performance of the procedure.
A numerical level of supervision has been assigned to each Procedure code or HCPCS code in the Medicare Physician Fee Schedule Database.
Nurse Practitioners (NPs), Clinical Nurse Specialists (CNSs) and Physician Assistants (PAs) are not defined as physicians. Therefore, they may not function as supervisory physicians under the diagnostic test benefit.
Under the statutory diagnostic test benefit, a physician must furnish the supervision when technicians perform diagnostic tests.
This means that NPs, CNSs and PAs may not supervise technicians performing diagnostic tests requiring either direct or personal supervision in the office setting in the absence of the physician (e.g., physician at the hospital or on vacation).
However, when personally performing diagnostic tests under their own statutory benefits, NPs, CNSs and PAs do not need to comply with the physician supervision requirement. Instead, they may perform diagnostic tests pursuant to state scope of practice laws and under the applicable state requirements for physician supervision or collaboration.
TrailBlazer Web Site
To determine the appropriate level of physician supervision:
1. Go to the Medicare Fee Schedule on the TrailBlazer Web site: http://www.trailblazerhealth.com/Tools/Fee Schedule/MedicareFeeSchedule.aspx.
2. Enter the technical component of the code (even if the total component is being performed).
3. Check the “Physician Supervision of Diagnostic Procedures” indicator. The green question mark box will provide an explanation of the indicator.