level of physician supervision to report clinical staff services with direct patient contact

by Lamont Buckridge 5 min read

Let Me Be Direct About Physician Supervision Requirements

16 hours ago Whereas only a physician may provide supervision for outpatient diagnostic services, nonphysician practitioners (NPPs) including “clinical psychologists, licensed clinical social … >> Go To The Portal


What are the guidelines for providing physician supervision in CMS?

CMS guidelines specify, “Documentation maintained by the billing provider must be able to demonstrate that the required physician supervision is furnished.”

What is direct supervision in a physician office?

2. Direct supervision: The meaning of “direct supervision” varies according to the precise location at which the service is provided: In the physician office, the supervising physician must be present in the office suite and immediately available to furnish assistance and direction throughout the procedure’s performance.

Can a clinical supervisor give professional direction based on experience?

However, it should be understood that there might be opportunities in which the clinical supervisor chooses to give professional direction based on experience, expertise, and/or for ethical or safety concerns. Clinical supervision is delivered within the supervisor’s professional practice license and ethical standards.

What are the different levels of physician supervision for diagnostic tests?

The level of physician supervision for diagnostic tests varies based on the complexity of the service. For most of these services, three levels of physician supervision are applicable: general, direct, and personal (42 CFR 410.32).

What is the difference between 99415 and 99417?

CPT 99417 Description: CPT 99417 may be used for every extra 15 minutes beyond the minimum required time for CPT Code 99205 or CPT Code 99215. CPT 99417 may be used when the provider spends extra time on outpatient E&M services or an office.

What is a 99212?

CPT® code 99212: Established patient office or other outpatient visit, 10-19 minutes.

When should I use 99358?

Codes 99358 and 99359 are used for non-face-to-face prolonged services by the billing physician/NP/PA when provided in relation to an E/M service on the same or different day as an E/M service. Beginning in 2021, you may not report these services on the same day as codes 99202-99215, office visit codes.

When should I use 99072?

Answer: Code 99072 may be reported with an in-person patient encounter for an office visit or other non-facility service, in which the implemented guidelines related to mitigating the transmission of the respiratory disease for which the PHE was declared are required.

What is a Level 2 visit?

Level 2 Established Office Visit (99212) This is the second lowest level of care for an established patient being seen in the office. Internists used this code for 2.04% of these encounter in 2019.

What is the difference between 99212 and 99213?

A tip for billing 99212 is that the presenting problems are usually self-limited or minor. Typically, 10 minutes are spent face-to-face with the patient and/or family. A tip for code 99213 is to think of expanded visits as a sum of the continued symptoms or another extended form of the problem.

Can 99358 be used for telephone calls?

Prolonged Services with Telephone calls (page 123) Non-Face-to-face prolonged service codes, 99358‒99359 can be billed with telephone services (99443 and 98968 would be reported for the first 30 minutes). 99358‒99359 are also allowed for telehealth visits.

Can 99358 be billed with 99214?

Do not report 99358, 99359 on the same date of service as 99202, 99203, 99204, 99205, 99212, 99213, 99214, 99215, 99417.

Who can bill CPT 99358?

Code 99358 may be reported in addition to any level of E/M service in the outpatient, inpatient, or observation setting (e.g., 99231, 99213, 99244), except 99211 and must be performed by a physician or other qualified healthcare professional (QHP).

Who can use CPT code 99072?

The American Medical Association (AMA) released new CPT code 99072, which became effective on Sept. 8, 2020. The code is designed for practices to report expenses incurred during a Public Health Emergency (PHE), including supplies and additional clinical staff time.

What does CPT code 99070 mean?

Unlisted Supplies and MaterialsUnlisted Supplies and Materials (CPT® Code 99070) CPT procedure 99070 is the code to bill for physicians' unlisted supplies and materials used in non-surgical procedures. If more than one claim line for 99070 is used for the same date of service, the additional line(s) will be denied.

What is code 87635?

87635 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique.

What is clinical supervision?

Clinical Supervision is conducted in a manner that ensures adequate attention to each supervisee and quality oversight for the cases; Clinical Supervision occurs frequently and follows a structured process that includes individual & group, clinical oversight, and regular access to supervisors;

What do clinical supervisors need to document?

Clinical Supervisors will document date, duration, and the content of supervision session for their supervisee (s), which may include a professional development plan. All documents pertaining to clinical supervision will be readily available to the supervisee.

What is group supervision?

In addition to reinforcing multi-disciplinary teaming, group supervision can serve as a good teaching/training venue in which provider trends are highlighted (e.g. engagement, population profiles, and the presenting severity/types of disorders, theoretical orientation and case conceptualization.) The Clinical Supervisor’s experiences in group supervision can also inform and strengthen the work of the entire team through the use of a recognized Clinical Practice Improvement model.

What is frontline practice?

This practice framework sets forth the actions/functions used by frontline practitioners to partner with a person receiving services to bring about positive life changes that assist the person by maintaining successes and managing challenges as they occur. Typical activities in practice include engaging the client and other key stakeholders in a connected, unifying effort through teamwork and fully understanding the person, their needs and environment. It also includes collaboratively defining results to be achieved, selecting and using intervention strategies and supports, resourcing and delivering planned interventions and supports, and tracking and adjusting intervention strategies until desired outcomes are achieved.

What is the function of quality practice?

Basic Expectations of High Quality Practice: There are five basic functions of quality practice that must be performed for each person served to achieve the greatest benefits and outcomes.

What is the purpose of practice?

The purpose of practice is to help a person or family to achieve an adequate level of: Well-being (e.g., safety, stability, permanency for dependent children, physical and emotional health), Daily functioning (e.g., basic tasks involved in daily living, as appropriate to a person’s life stage and ability),

What is practice framework?

The practice framework also encompasses the core values and expectations for providing services. The framework functions to organize casework and service delivery, to guide the training and supervision of staff, and clarifies quality measures and accountability. Basic practice functions are illustrated in the “practice wheel” diagram below. The practice wheel can be utilized to guide supervision by providing a framework and expectations for working with persons receiving services. For example, supervision and training could progress along the practice wheel with each function as a topic of focus to strengthen and operationalize expectations.

What is the document required for a physician to perform a direct or general supervision?

For services requiring direct or general supervision, the provider performing the service should document the physician’s direction or presence in the office, as required by the level of supervision, and the physician should confirm with a signature.

Who provides direct supervision?

A physician may provide supervision at the required level (general, direct, or personal), or. An approved NPP may provide direct supervision for the service, as long as the NPP legitimately may perform the service him- or herself. In this context, “direct supervision” may be defined:

What is Medicare supervision?

Medicare supervision requirements apply to outpatient services in both the hospital setting and the physician office. Following physician supervision requirements is crucial for compliance and reimbursement. Services not meeting applicable guidelines are considered “not reasonable and necessary,” and are ineligible for Medicare payment; however, ...

What is the role of the physician in a diagnostic test?

The physician must order the diagnostic test and is responsible for training staff performing the tests, as well as maintaining the testing equipment.

Can an NPP supervise a hospital?

The NPP must be privileged by the hospital to perform the services he or she supervises, and must abide by any applicable hospital physician-collaboration or supervision requirements. An NPP may not supervise a service he or she cannot perform personally.

Is incident to requirement required for diagnostic testing?

Incident-to requirements are not applicable to diagnostic testing in the office setting. The Medicare Benefit Policy Manual, chapter 15, § 80 states, “Diagnostic tests may be furnished under situations that meet the incident to requirements but this is not required.”.

Can a doctor of osteopathy be a supervisory physician?

For diagnostic services in an outpatient setting (hospital outpatient or physician office), only “a doctor of medicine or osteopathy legally authorized to practice medicine in his or her state of practice,” as defined by §1861 (r) of the Social Security Act, may act as a supervisory physician.

When a student arrives in a clinical setting, what is the supervisor's role?

It is recommended that when a student arrives in a clinical setting, a supervisor provides an opportunity for the student to observe a faculty or resident for the first session. Thereafter, they should begin to see patients on their own.

Who must personally perform physical exam and medical decision making activities of the E/M service being billed?

The teaching physician must personally perform (or re-perform) the physical exam and medical decision making activities of the E/M service being billed, but may verify any student documentation of them in the medical record, rather than re-documenting this work.”.

Who must be chaperoned for intimate exam?

Students participating in an intimate exam with a patient must have a chaperone with them, irrespective of the gender of the patient or the student. The chaperone must be an MD/DO (residents included), NP, PA, or CNM. Permission to participate in an intimate exam must be obtained by the supervisor in advance of the examination itself. The patient has the right to decline student attendance at any examination. If a student is unable to perform any intimate exam due to patient preference, the student’s evaluation will not be impacted and if necessary, the clerkship director will provide an alternative experience.

How many focused visits per day for a syringe?

In the outpatient setting, it is recommended that the student should initially perform 4-5 focused visits per day in the first week, increasing to 6-12 thereafter. In the inpatient setting, the student should initially follow 1-2 patients and increased to 3-4 thereafter.

Can students write notes on patient electronic charts?

Students are allowed and encouraged to write complete notes in patient electronic charts as designated by the site and the site’s documentation policy. Supervisors must review all student documentation that is used for billing.

Can a patient decline an exam?

The patient has the right to decline student attendance at any examination. If a student is unable to perform any intimate exam due to patient preference, the student’s evaluation will not be impacted and if necessary, the clerkship director will provide an alternative experience.

What is Medicare Administrative Contractor?

The Medicare Administrative Contractor is hereby advised that this constitutes technical direction as defined in your contract. CMS does not construe this as a change to the MAC Statement of Work. The contractor is not obligated to incur costs in excess of the amounts allotted in your contract unless and until specifically authorized by the Contracting Officer. If the contractor considers anything provided, as described above, to be outside the current scope of work, the contractor shall withhold performance on the part(s) in question and immediately notify the Contracting Officer, in writing or by e-mail, and request formal directions regarding continued performance requirements.

What is extended duration therapeutic services?

These are outpatient therapeutic services that can last a significant period of time, have a substantial monitoring component that is typically performed by auxiliary personnel, have a low risk of requiring the supervisory practitioner’s immediate availability to furnish assistance and direction after the initiation of the service, and that are not primarily surgical in nature. In the provision of these services, CMS requires a minimum of direct supervision during the initiation of the service which may be followed by general supervision for the remainder of the service at the discretion of the supervisory practitioner. The CMS OPPS Website at

What are therapeutic services and supplies?

Therapeutic services and supplies which hospitals provide on an outpatient basis are those services and supplies (including the use of hospital facilities and drugs and biologicals that cannot be self-administered) which are not diagnostic services, are furnished to outpatients incident to the services of physicians and practitioners and which aid them in the treatment of patients. These services include clinic services, emergency room services, and observation services. Policies for hospital outpatient therapeutic services furnished incident to physicians’ services differ in some respects from policies that pertain to “incident to” services furnished in office and physician-directed clinic settings. See Chapter 15, “Covered Medical and Other Health Services,” Section 60.

What is the definition of physician supervision?

Background: The Physician Supervision of Diagnostic Procedures indicator specifies a level of physician supervision required for certain diagnostic tests. The levels of supervision are "general," "direct," and "personal" supervision, and each of these levels of supervision have a corresponding indicator value assigned to each diagnostic procedure.

Who is the pre implementation contact for the HHS?

Pre-Implementation Contact(s): Gail Addis, 410-786-4522 or Gail.Addis@cms.hhs.gov, Patrick Sartini, 410 786-6952 or Patrick.Sartini@cms.hhs.gov (For information on the revision of the definition of the physician supervision of diagnostic services.), Kathleen Kersell, 410-786-2033 or kathleen.Kersell@cms.hhs.gov.

What is Medicare Administrative Contractor?

The Medicare Administrative Contractor is hereby advised that this constitutes technical direction as defined in your contract. CMS does not construe this as a change to the MAC Statement of Work. The contractor is not obligated to incur costs in excess of the amounts allotted in your contract unless and until specifically authorized by the Contracting Officer. If the contractor considers anything provided, as described above, to be outside the current scope of work, the contractor shall withhold performance on the part(s) in question and immediately notify the Contracting Officer, in writing or by e-mail, and request formal directions regarding continued performance requirements.