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So Ron et al had a brief moment in the sun with the 3 month window between the start of the new general supervision rules on January 1st 2020 and the start of the PHE. We barely had time to argue about that because it was more about APM at the time.true, but he is by far the worst. He once claimed it is fraud if you bill for a cbct at a satellite (covered by another doctor) when you review the film remotely.
Then, with virtual direct supervision...even if you want to claim IGRT is diagnostic requiring direct supervision, it doesn't matter - we all have the ability to engage in virtual supervision. Side note, outside of Ron and ASTRO, the only other place you can find "IGRT is a diagnostic test" is from a single MAC (Palmetto) and not even an LCD, just an article (LCA) - and even then the LCA gets real cute with using the word "physician" not "Radiation Oncologist", though they make sure to specify "Radiation Oncologist" for 77427/OTV.
Virtual supervision, barring some random craziness, will likely become permanent. Which means...what else can they cling to for this?
The current flavor of "saber rattling" is this - site of service. They acknowledge the supervision rules apply to the technical component, and in hospital outpatient departments, billing technical under general is OK (per CMS guidelines, obviously individual hospitals or practices or various accreditations or whatnot might not, but that's an individual thing).
They are no longer flat out saying general supervision for IGRT is wrong, they're saying that you need to bill the professional component using the address where the service was provided.
The unspoken leaps of logic there being if you approve IGRT images remotely, from home for example, and your practice bills CMS using the hospital address on line 31 of the 1500 form or whatever, you're committing fraud.
Small problem...what about that entire industry of Teleradiology that has existed forever?
Long story short, CMS cares about zip code (for MAC jurisdiction) as well as facility vs non-facility for fee scheduled. The "default" recommendation is to bill the professional using the same address as the technical, with the example CMS gives being a scenario where a doctor orders a knee MRI, patient has it done at a hospital closer to home, ordering doctor interprets the test in their office.
Some same zip code, same fee schedule - CMS gets what they need if the address on the 1500 is the hospital where the MRI was performed.
There's other nuances and allowances for this of course. But I know a lot of people will spend all day at their clinic and then catch up on work at night, including offline review.
If Ron and friends are correct, they're opening up the dumbest version of Pandora's Box they possibly could.