Understanding physician supervision levels

Here is a good summary provided by Part B Insider newsletter (www. Partbinsider.com):

Question: Our carrier asked us to verify that our tech performed a patient’s elbow MRI under direct supervision from the surgeon. What does this mean?

Answer: The Medicare physician fee schedule supervision indicators show the physician supervision level required for a diagnostic test if it’s performed in a physician office, imaging center or independent diagnostic testing facility (IDTF). Important: These rules don’t apply to diagnostic tests performed in an inpatient or outpatient hospital setting.

First, you must understand each level of supervision because the fee schedule lists them in number format (such as “01,” “02” and so on). You can find explanations of the supervision levels in Medicare’s Internet Only Manual (IOM) 100-02l, Chapter 15, Section 80. The following examples can show you what certain supervision levels mean:

Level 0 or 09: Procedures listed in these categories are not subject to the supervision requirements.

Level 01 refers to general supervision. What this means: The physician must provide direction and control during the procedure. For example, most payers only require general supervision during plain x-ray films.

Level 02 is direct supervision. What this means: The physician must be present in the office suite and immediately available to furnish assistance and direction, but the physician does not have to be in the room where the patient undergoes the test. Examples of procedures requiring direct supervision include joint MRIs with contrast materials (such as 73222 and 73220, among others), certain CT scans (such as CTs of the lumbar spine with and without dye, 72133), and several other procedures.

Level 03 is personal supervision. What this means: The physician must be in attendance in the room during the procedure. For example, you must perform an ischemic limb exercise test (95875) under personal supervision.

Level 06 means that a physician or a certified physical therapist must perform the procedure.

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