Question:

Can you tell me more about how “direct supervision” was defined prior to the public health emergency for pulmonary rehabilitation and tobacco counseling services?

Answer:

Prior to the COVID-19 Public Health Emergency (PHE), CMS rules have traditionally stated that non-physician practitioners, (physician assistants, nurse practitioners, and others) are not permitted to provide “direct supervision” under the PR program in either the physician office or hospital outpatient setting. This also applied to cardiac rehabilitation (CR) and intensive cardiac rehabilitation (ICR). CMS maintained that the law is very specific in using the term “physician” for supervised programs and that there was no flexibility in expanding the definition to include non-physician practitioners. “Direct supervision” by definition required the physician to be “present on the same campus and immediately available to furnish assistance and direction throughout the performance of the procedure.”

This question was answered in our Coding Essentials for RT/Pulmonary Function. For more hot topics relating to respiratory services, please visit our store or call us at 1.800.252.1578, ext. 2.

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