Awareness : Newsletter Articles

Supervision Requirements Diagnostic X-Ray, Diagnostic Laboratory, and Other Diagnostic Tests

When providing the technical component of diagnostics tests for a patient who is not a hospital inpatient or outpatient, levels of physician supervision are required. 

Under Medicare regulation (Section410.32(b) of the Code of Federal Regulations), have to be performed under the supervision of a physician as defined by Medicare in order to be considered reasonable and necessary. 

General Supervision: the procedure is furnished under the physician’s overall direction and control.  However, the physician’s presence is not required during the performance of the procedure.  Under general supervision, the non-physician staff performing the diagnostic procedure and maintenance of the equipment and supplies are the continuing responsibility of the physician. 

Direct Supervision: in the office setting, the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician must be present in the room when the procedure is performed.

Personal Supervision: means a physician must be in attendance in the room during the performance of the procedure.

One of the following numerical levels are assigned to each CPT or HCPCS code:

  • 0: Procedure is not a diagnostic test or procedure is a diagnostic test which is not subject to the physician supervision policy.
  • 1: Procedure must be performed under the general supervision of a physician.
  • 2: Procedure must be performed under the direct supervision of a physician.
  • 3: Procedure must be performed under the personal supervision of a physician.
  • 4: Physician supervision policy does not apply when procedure is furnished by a qualified, independent psychologist or a clinical psychologist or furnished under the general supervision of a clinical psychologist; otherwise must be performed under the general supervision of a physician.
  • 5: Physician supervision policy does not apply when procedure is furnished by a qualified audiologist; otherwise must be performed under the general supervision of a physician.
  • 6: Procedure must be performed by a physician or by a physical therapist (PT) who is certified by the American Board of Physical Therapy Specialties (ABPTS) as a qualified electrophysiologic clinical specialist and is permitted to provide the procedure under State law.
  • 6a: Supervision standards for level 66 apply; in addition, the PT with ABPTS certification may supervise another PT but only the PT with ABPTS certification may bill.
  • 7a: Supervision standards for level 77 apply; in addition, the PT with ABPTS certification may supervise another PT but only the PT with ABPTS certification may bill.
  • 9: Concept does not apply.
  • 21: Procedure must be performed by a technician with certification under general supervision of a physician; otherwise must be performed under direct supervision of a physician.
  • 22: Procedure may be performed by a technician with on-line real-time contact with physician.
  • 66: Procedure must be performed by a physician or by a PT with ABPTS certification and certification in this specific procedure.
  • 77: Procedure must be performed by a PT with ABPTS certification or by a PT without certification under direct supervision of a physician, or by a technician with certification under general supervision of a physician.

Nurse practitioners, clinical nurse specialists, and physician assistants are not defined as physicians under §1861(r) of the Act. Therefore, they may not function as supervisory physicians under the diagnostic tests benefit (§1861(s)(3) of the Act). However, when these practitioners personally perform diagnostic tests as provided under §1861(s)(2)(K) of the Act, §1861(s)(3) does not apply and they may perform diagnostic tests pursuant to State scope of practice laws and under the applicable State requirements for physician supervision or collaboration.