What are the Physician Supervision Levels?
Image guided radiation therapy services are considered diagnostic x-ray services by CMS and therefore must follow the same supervision requirements as other diagnostic x-ray tests. When these services are performed by hospital outpatient departments and freestanding radiation therapy centers to assist in the accurate placement of radiation fields (i.e., image guidance services) the services must be furnished under the supervision of a physician. It’s important for radiation oncologists to know the different levels of physician supervision to ensure they are meeting the appropriate level of supervision. Further, it’s important to keep in mind that services furnished without the required level of physician supervision are not covered under Medicare.
Federal Regulations define three different levels of physician supervision required for the various diagnostic imaging tests used in image-guided radiation therapy (IGRT).
General Supervision: The procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. (76950 or G6001 - Ultrasonic guidance for placement of radiation therapy fields and 77417- Therapeutic radiology port film(s))
Direct Supervision: The physician must be present and immediately available to furnish assistance and direction throughout the performance of the procedure. The physician does not need to be present in the room when the procedure is performed. (77014 – Computed tomography guidance for placement of radiation therapy fields, G6002 Stereoscopic X-ray guidance for localization of target volume for the delivery of radiation therapy, and 77387 Guidance for localization of target volume for delivery of radiation treatment delivery)
Personal Supervision: The physician must be in attendance in the room during the performance of the procedure. (76965 - Ultrasonic guidance for interstitial radioelement application)
What are the Documentation Requirements for Physician Supervision?
It’s important for Radiation Oncology providers to understand the documentation requirements of physician supervision levels. For example, to support that the direct supervision requirement has been met, the images and shifts are to be reviewed and approved by the radiation oncologist prior to the patient’s next treatment. Appropriate documentation could be a note in the patient’s chart or a physician’s electronic signature on the shifts/images. A unique daily note is not required. Your radiation oncology billing department will thank you for following these guidelines!