The following information focuses on important issues relating to the practice of radiation oncology.
ASTRO White Paper on Physician Supervision Requirements
ASTRO has received countless questions from members regarding the Medicare requirements related to physician supervision of radiation therapy and other services over the years. The recent discussions of physician supervision requirements in the outpatient hospital setting in the Hospital Outpatient Perspective Payment System (HOPPS) Proposed and Final Rules for 2009 have raised even more questions for ASTRO members. It is clear that our members want to ensure compliance with all Centers for Medicare and Medicaid Services (CMS) supervision requirements, regardless of practice setting. The answers to these questions are not simple. ASTRO strongly encourages all radiation oncologists to work closely with their compliance officers and/or hospital administrators to ensure compliance with all Medicare supervision requirements.
CMS is responsible for administering the Medicare program. Over the years, Medicare’s policies related to physician supervision requirements have been issued through regulations or through instructions to Medicare carriers in various manuals. The policies on physician supervision requirements that are pertinent to radiation oncologists relate to five specific benefits to which Medicare beneficiaries are entitled by law (Title XVIII of the Social Security Act). The ASTRO “Medicare’s Physician Supervision Requirements” paper attempts to simplify the physician supervision requirements related to the following five categories.
- Diagnostic tests in an office or free-standing radiation therapy center.
- Diagnostic tests in an outpatient hospital setting.
- “Incident to” services in an office or free-standing radiation therapy center.
- “Incident to” services in an outpatient hospital setting.
- Radiation therapy in an office or free-standing radiation therapy center.
The paper does not address issues related to credentialing or privileging.