Staff Supervision Requirements for Delegated Services
DESCRIPTION
This policy defines BlueCross BlueShield of Tennessee (BCBST) requirements for supervision by eligible physicians and chiropractors of their associates and assistants. Supervision by itself does not create eligibility for the services of associates and assistants. Such practitioners must be supervised as specified in the categories below for a service to be eligible for reimbursement. The policy also describes requirements for billing delegated services. To the extent that state or federal law or regulation exceeds these internal requirements, these laws or regulations will control.
Licensed Medical doctors (MDs), Doctors of Osteopathy (DOs), Doctors of Chiropractic (DCs), Doctors of Podiatric Medicine (DPMs), Licensed Professional Counselors (LPC), and Licensed Clinical Social Workers Social Workers (LCSW) are examples of autonomous providers. Their services do not require the supervision of another profession. These practitioners should bill their services under their own provider number or the provider number of their facility. (Refer to clarification of term "autonomous" under Additional Information below.)
See also: Staff Practitioners to Whom Services May Be Delegated
POLICY
Licensed Providers Requiring Supervision by Retrospective Review - Certified Nurse Midwife, Certified Registered Nurse Anesthetist (for information regarding the direction and supervision of Certified Registered Nurse Anesthetists refer to Medical Policy Manual Glossary document titled Anesthesia Definitions), Licensed Resident Physician, Nurse Practitioner, Physician Assistant.
Supervising physicians or chiropractors are required to perform a review of the services they delegate to this category of practitioner. Practitioners in this category are required to bill under the billing number of their supervising practitioner except when rendering services independently, and are eligible to bill directly under their own BCBST provider billing number. The actual provider of service must also be listed on the billing form. This does not apply to licensed residents when performing services that are a part of their residency program.
Supervising physicians and chiropractors must:
Annually review and document the licensure or certification of any office staff or employee to whom they delegate medical services.
Review the patient records and certify by signed notation that evaluations and treatment plans are appropriate, as prescribed by law.
Licensed or Certified Providers Requiring Minimal Supervision - Certified Athletic Trainer, Certified Audiologist, Certified Occupational Therapist, Chiropractic Radiology Technician, Licensed Physical Therapist, Licensed Practical Nurse, Licensed Psychological Examiner, Medical Laboratory Technologist, Orthopedic Physician Assistant, Radiologic Technologist, Registered Dietitian/Registered Nutritionist, Registered Nurse, Registered Respiratory Therapist, Speech and Language Pathologist. Some practitioners within these healthcare fields may be eligible for a BlueCross BlueShield of Tennessee provider ID number.
Supervising physicians, chiropractors, or psychologists are required to supervise the provision of delegated services for this category of providers. If the actual provider of service needs the direction or supervision of a chiropractor, physician or psychologist to legally perform a service and is ineligible to bill under their own number, then the chiropractor, physician or psychologist will be allowed to bill those services under their name and provider number. The actual provider of service must also be listed on the billing form (i.e., in block number 31 of the HCFA 1500 claim form).
Supervising Physicians, Chiropractors and Psychologists must:
Annually review and document the licensure or certification of any office staff or employees to whom they delegate medical services.
Only delegate services that are within the scope of the practitioner's certification or license as determined by law. Such services should not require the exercise of independent professional judgment.
Include the following documentation: 1) an evaluation of the patient prior to delegating or ordering any services, 2) a specific order for the service to be delegated, and 3) notation of the results obtained from the service ordered.
Certified Providers Requiring Direct and Close Supervision - Certified Chiropractic Therapy Assistant, Certified Medical Assistant, Certified Nursing Assistant, Certified Occupational Therapy Assistant, Certified Podiatric Assistant, Licensed Physical Therapy Assistant, Medical Laboratory Technician, Speech Language Pathology Assistant. These healthcare practitioners are not eligible for a BlueCross BlueShield of Tennessee provider ID number.
Supervising Physicians, Chiropractors and Therapists must:
Annually review and document certification of any office staff or employees to whom they delegate medical services.
Only delegate services in which the supervising practitioner materially participates. "Materially participate" means the supervising practitioner must evaluate the patient immediately prior to the service, prepare a detailed written order, and perform a final evaluation of the patient and the service performed prior to the patient leaving the facility. The final evaluation should ensure that the service was delivered appropriately and was clinically effective. The supervising practitioner must be on-site and available at all times. Documentation in the patient medical record must reflect that these steps occurred.
Follow required treatment protocols from nationally recognized sources. Protocols must be kept onsite and be made available for review by BCBST.
Under extenuating circumstances (e.g., network inadequacy in rural areas) a licensed / certified therapy assistant may render services through a home health provider in the home health setting under the general supervision of a licensed therapist. Under these conditions, a licensed therapist must evaluate the patient, develop a treatment plan, and implement the plan. General supervision requires initial direction and periodic re-evaluation by the registered therapists; however, the supervisor does not have to be physically present or on the premises.
ADDITIONAL INFORMATION
Clarification of terms used within this policy:
Autonomous providers - Providers who by their state license are qualified to diagnose and initiate treatment independently. For example, a Doctor of Chiropractic (DC) is licensed to diagnose and initiate chiropractic treatment without an order to treat from another profession. A DC is an autonomous provider and as such, does not require supervision or orders from another profession.
Supervision by retrospective review - Supervision that does not take place during the time that a service is performed, but after the service has been rendered. This form of supervision may take place several days or even weeks after a service was rendered and may merely involve a review of an individual's medical record (i.e., complaints, signs, symptoms, diagnostics and subsequent treatment[s]). The supervising practitioner is typically not within the place of service (i.e., facility, office) during the time that a delegated service is performed.
Minimal supervision - Requires that the supervising/treating practitioner evaluate the patient at some reasonable time prior to receiving a delegated service, that a specific written order for the service be issued prior to the service being performed, and that a notation be made of the results obtained from the delegated service. The supervising/treating practitioner may or may not be within the place of service (i.e., facility, office) during the time that a delegated service is rendered.
Direct and close supervision - Requires that the supervising practitioner has, at a minimum, face-to-face contact with the patient immediately before and after a service is received. Material participation by the supervising practitioner must include evaluation of the patient immediately prior to the service, a detailed written order, and a final evaluation of the patient and the service performed prior to the patient leaving the facility. The supervising practitioner must be within the place of service (i.e., facility, office) and readily available during the time that a delegated service is rendered. (Note: Extenuating circumstances under section 3, bullet e above.) Being available via telephone does not constitute direct and close supervision.
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EFFECTIVE DATE |
3/28/2007 |
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