How well do you know your role as a supervising physician in your outpatient imaging facility? Remember you’re on the hook, so here’s what to do before CMS compliance comes knocking.
How well do you know your role as a supervising physician in your outpatient facility? Not very well? Well like it or not, CMS says you have to know that role and fulfill it. Recently there have been several settlements relating imaging supervision by CMS, so it should be on your group’s radar.
Most of us are aware that there are requirements for this, and some of us sign off as supervising physicians for our hospital imaging centers or independent testing facilities (IDTF). But do you really know the rules? And how do you find out if the rules change? Did you know that the rules depend on your local Medicare carrier's requirements, not just national regulations?
Probably like many of you, I'm not a lawyer, and the rules are complex and subject to interpretation even for lawyers. That might prompt some of us to throw up our hands and say it is just too much to deal with. But remember you are on the hook, at a minimum for civil penalties, if you aren't doing this properly. And CMS doesn't let you claim ignorance once you sign off as the supervising physician.
So what to do?
Learn the rules and pay attention. Several articles in the ACR bulletin recently outlined current interpretations and are valuable. Moreover, the ACR is available to help you with such matters. They have a legal office that can give you direction, and if your needs are more extensive they can formally assist you or refer you to someone local to help.
If you are partnered with an IDTF, see if their compliance office or legal department can give you guidelines. Just remind them that they are responsible too, and that should be incentive enough for them to help you get it right.
Check what you are signing. Don't sign off as the supervising physician without knowing exactly what you are attesting to. And that is what you are doing: legally attesting to knowing and following national and local rules. Often the local carrier expects you are qualified to supervise all radiological exams performed. If you don't read all types of studies, then you'll have to check with the carrier as to their legal requirements for qualification.
Work with your center. Of course, it is easiest for the IDTF to have just one person supervise. But they are also exposed to risk if you aren't properly qualified. That may not mean a lot to the technologists asking you to sign off, but it may to the center manager or owner, so explain it to them if needed. Have them check with the CMS local carrier as to rules. If one person suffices that is great. But if not you'll need to create a slate of supervising physicians with necessary qualifications.
Once you’ve done this, create a checklist of the rules and make sure all of them are fulfilled. Assign someone to update and check on them with compliance regularly.
Remember, ignoring the rules won’t help you when CMS compliance comes knocking.