UCR 132: FAQs - Direct supervision / incident to

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UCR 132: Direct supervision / incident to, independent interpretation when own CT / US, billing creatinine if own equipment, and can MA or Tech sign PVR or EMG?

February 10, 2023

Mark, Ray, and Scott discuss questions and current topics.

"Good afternoon,
Our practice has a lot of mid-level physicians. The question has arose about “direct' supervision and provider being immediately available. I provided the below-
How does Medicare define direct physician supervision?

Direct supervision: The physician or AP providing supervision must be “immediately available” and “interruptible” to provide assistance and direction throughout the performance of the procedure; however, he or she does not need to be present in the room when the procedure is performed.

One of the mid levels shared this: In the office but not immediately available. Remind physicians that they should not perform procedures while supervising incident-to visits. The supervising physician must be able to drop what they are doing right away, even if the physician is performing a relatively simple procedure such as a trigger point injections, that would break the requirement that the physician be ready if the non-physician practitioner needs help or guidance.

Now I am getting all kinds of questions.

The rule above is only pertaining to “incident to” situations correct? if the APP is listing a supervising provider for the day for insurance purposes only: such as the insurances that don't recognize /credential mid-levels (UHC for instance) would/should you follow the same rule as above? How are other practices handling this?
Hello *Independent Interpretation of test*

If we own the CT and US machines can our providers still get credit for interpreting films done in our office? We do bill these studies global once the radiologists does his reading.
Our office has purchased equipment to start doing creatinine tests (82565) on contrast CT patients in the office. Is this billable? And what codes would we bill? What are the documentation requirements?
If I bill only for CPT 51798 and 51741. Can only the MA /technician being the signer or does it need to be MD as a billing provider.

Thank you!