MedPAC weighs in on Physician Supervision

The Medicare Payment Advisory Commission (MedPAC) released a report to the Congress on physician supervision requirements in critical access hospitals and small rural hospitals on Friday, December 1, 2017. This report was required under provisions of the 21st Century Cures Act. The analysis focuses on both the quality of care and economic impact of the moratorium.

In summary, NRHA agrees with the central recommendation of their report that “CMS should present hospitals with physician supervision requirements that are specific and clear but also allow hospitals flexibility in how they meet those requirements.”

Furthermore, they go on to say, “the Commission believes that hospitals need further clarity from CMS on how the agency defines “immediately available” and “interruptible” in the direct supervision requirement for outpatient therapeutic services.”

This is all in the context of the reality of physician shortages and that these forms of clarity can improve quality of care and increase access. Also, Telehealth was another tool to consider in meeting requirements of physician supervision.

We agree with these conclusions, however, the devil is in the details. Asking CMS for clarity is a high-risk behavior. Historically, CMS “clarity” made things worse. But, with the Rural Health Council at CMS and their hopeful significant input into any process to define these two issues, there would be a reasonable expectation to see this matter resolved for the long-term. In the meantime, we need the moratorium on the enforcement of physician supervision requirements.
 

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