Is general supervision the minimum requirement for an on-campus Hospital based infusion center? Will this continue after PHE ends?
I am finding conflicting data regarding supervision requirements for chemotherapy administration at an on-campus Hospital based infusion center. Is it direct supervision or general?
Answer
Thank you for your question.
This CMS document provides some information about emergency waivers and other flexibilities used to deal with the Covid-19 emergency. I have linked directly to the section about Medicare physician supervision requirements.
Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19
Another publication that may be helpful is "CY 2020 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS-1717-FC)"
The document includes this paragraph:
Rethinking Rural Health
Changes in the Level of Supervision of Outpatient Therapeutic Services in Hospitals and Critical Access Hospitals (CAHs)
CMS is finalizing a change to the generally applicable minimum required level of supervision for hospital outpatient therapeutic services furnished by all hospitals and CAHs from direct supervision to general supervision. General supervision means that the procedure is furnished under the physician's overall direction and control, but that the physician's presence is not required during the performance of the procedure. This change ensures a standard minimum level of supervision for each hospital outpatient therapeutic service furnished incident to a physician’s service. As stated in the final rule with comment period, this change does not preclude a hospital from requiring a higher level of supervision for certain services, as it determines appropriate.
See also this article from PubMed:
And finally, this blog post provides some explanation of the 2020 HOPPS final rule:
"The 2020 HOPPS final rule brings major changes to physician supervision—and more—for cancer programs"
We cannot provide legal advice or interpretation here, but if you contact CMS directly they should be able to answer any specific questions that are not explained in these documents. CMS contact information is available at https://www.cms.gov/about-cms/agency-information/contactcms
I hope this information is helpful. Let us know if the links don't work. If this is not what you need, or if you should require any further assistance, please let us know.
Bobby Griffith
Lead Government Information Reference Associate
Sycamore Library
University of North Texas Libraries