Requests For Supervision Level Changes For Hospital Outpatient Therapeutic Services

On Friday, December 16th, CMS published notice CMS-1586-N announcing the first semi-annual meeting of the Advisory Panel on Hospital Outpatient Payment. This panel advises CMS on the clinical integrity of the APC groups and their associated weights and will now also review hospital outpatient supervision issues. The first meeting is scheduled for February 27, 28, and 29 and the agenda will include supervision of hospital outpatient therapeutic services. Presentations and written requests are due December 30, 2011 by 5 p.m. EST. Stakeholders interested in submitting requests for the February 2012 meeting for a change in the required supervision level for a given service should follow the presentation submission instructions in the notice and consider the following information from the 2012 OPPS/ASC final rule (76 Fed. Reg. 74370): The Panel will be charged with recommending to CMS a supervision level (general, direct, or personal) that will ensure an appropriate level of quality and safety for delivery of a given service, as defined by a HCPCS or CPT code. In recommending a supervision level to CMS, the Panel will assess whether there is a significant likelihood that the supervisory practitioner would need to reassess the patient and modify treatment during or immediately following the therapeutic intervention, or provide guidance or advice to the individual who provides the service. In answering that question, the Panel will consider the following factors but may also consider others as appropriate: Complexity of the service; Acuity of the patients receiving the service; Probability of unexpected or adverse patient event; Expectation of rapid clinical changes during the therapeutic service or procedure; Recent changes in technology or practice patterns that affect a procedure's safety; The clinical context in which the service is delivered. All requests for a change in the required supervision level must include justification for the change in supervision level that is sought per HCPCS code, supported to the extent possible with clinical evidence. Please refer to the 2012 OPPS/ASC final rule for further information.