BlueCross BlueShield of Tennessee Administrative Services

Staff Supervision Requirements for Delegated Services


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. 

A Licensed Medical Doctor (MD), Doctor of Osteopathy (DO), Doctor of Chiropractic (DC), Doctor of Podiatric Medicine (DPM), Licensed Professional Counselor (LPC), Licensed Clinical Social Worker (LCSW), and Licensed Pharmacist 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 billing number or the provider number of their group or facility.  (Refer to clarification of term "autonomous" under Additional Information below.)

The supervision requirements noted below are not applicable to Licensed Physical Therapists, Certified Occupational Therapists, Speech and Language Pathologists and Certified Audiologist.  

See also: Staff Practitioners to Whom Services May Be Delegated


  1. 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.

  2. Licensed or Certified Providers Requiring Minimal Supervision - Certified Athletic Trainer, Chiropractic Radiology Technician, Licensed Practical Nurse, Licensed Psychological Examiner, Medical Laboratory Technologist, Orthopedic Physician Assistant, Radiologic Technologist, Registered Dietitian/Registered Nutritionist, Registered Nurse, Registered Respiratory Therapist, Licensed Physical Therapy Assistant. Some practitioners within these healthcare fields may be eligible for a BlueCross BlueShield of Tennessee provider ID number.

  3. Certified Providers Requiring Direct and Close Supervision - Certified Chiropractic Therapy Assistant, Certified Medical Assistant, Certified Nursing Assistant, Certified Occupational Therapy Assistant, Certified Podiatric Assistant, Medical Laboratory Technician, Speech Language Pathology Assistant.  These healthcare practitioners are not eligible for a BlueCross BlueShield of Tennessee provider ID number.

    The supervising MD, DO, DC, therapist (e.g., Certified Occupational Therapist, Speech and Language Pathologist) must:

    1. Annually review and document certification of any office staff or employees to whom they delegate medical services.

    2. 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.

    3. Follow required treatment protocols from nationally recognized sources.  Protocols must be kept onsite and be made available for review by  BCBST.

    4. Only delegate services that do not require clinical judgment, or could not be construed as a service requiring the expertise of practitioners in categories 1&2.


Clarification of terms used within this policy:

Autonomous providers - Those Providers that are recognized by BCBST’s policies and contractual agreements to provide services independently without referral or order from another provider to BCBST’s members and that are also qualified to diagnose and initiate treatment independently pursuant to the provider’s state license.   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.  Being available via telephone does not constitute direct and close supervision.



ID_PNC & Provider Credentialing

Policies included in the Medical Policy Manual are not intended to certify coverage availability. They are medical determinations about a particular technology, service, drug, etc. While a policy or technology may be medically necessary, it could be excluded in a member's benefit plan. Please check with the appropriate claims department to determine if the service in question is a covered service under a particular benefit plan. Use of the Medical Policy Manual is not intended to replace independent medical judgment for treatment of individuals. The content on this Web site is not intended to be a substitute for professional medical advice in any way. Always seek the advice of your physician or other qualified health care provider if you have questions regarding a medical condition or treatment.

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