In the Medicare Physician Fee Schedule 2019 Final Rule, The Centers for Medicare and Medicaid Services (CMS) revised their definition of the “Physician Supervision of Diagnostic Procedures” to specify that, beginning with dates of services January 1, 2019, diagnostic tests that are furnished by a Radiologist Assistant* require only a direct level of physician supervision, when permitted by state law and state scope of practice regulations. Supervision level by CPT code can be found here.
*Radiologist Assistants are defined as Registered Radiologist Assistants (RRAs) who are certified by The American Registry of Radiologic Technologists, and Radiology Practitioner Assistants (RPAs) who are certified by the Certification Board for Radiology Practitioner Assistants.
Key Points:
  • The supervision requirements apply to the technical component only of a diagnostic imaging study in the hospital outpatient setting as well an Independent Diagnostic Testing Facility (IDTF) and physician office. The professional component must be performed by a physician.
  • Certain tests previously classified as requiring personal supervision, meaning the physician must be present in the room, will now be classified as requiring direct supervision. Direct supervision requires only that the physician be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure.
    • Examples of affected procedures include: Fluoroscopy procedures such as Barium Swallow, UGI, BE, ERCP, Cystography, VCUG, Cystography
  • The supervision rule does not apply to interventional procedures because CMS does not classify these procedures as diagnostic tests. Per CMS, any interventional procedure must be performed and interpreted by the physician.
  • It is essential that physicians document any involvement by a radiologist assistant in their dictation along with the supervision level provided.
ADVOCATE will be hosting a webinar to provide further detail and clarity on physician supervision requirements in March – details to come!
As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.
Lauren Sloan, MHA, RD, LD
Director of Regulatory Affairs