Hospitals may be in a tight spot because CMS unexpectedly has changed the physician supervision requirement for certain outpatient therapeutic services provided "incident to" a physician’s services. Some experts believe the change may have been inadvertent, but it’s there in black and white all the same.
In Transmittal 82 (Change Request 5946), issued Feb. 8, CMS appears to impose a new requirement on services furnished in hospital outpatient departments with provider-based status. CMS says for the first time that "the services must be rendered under the direct supervision of a physician who is treating the patient."
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