A: Radiologist assistants (RAs) and radiology practitioner assistants (RPAs) are registered radiological technologists who have undertaken a higher level of education and training. RAs and RPAs are required to be supervised by a radiologist. Some radiology practices have hired physician assistants (PAs) and are training them to practice radiology.
Differences between radiologist assistants (RAs) and radiology practitioner assistants (RPAs) have emerged from differences in educational standards, impacting the level of practice and overall autonomy of RAs and RPAs in clinical practice. The RPA acronym, however, has caused some confusion, since it sometimes has been incorrectly associated with the benefits and requirements of the physician assistant (PA) designation.
Physician assistants (PA) differ from RAs in that PAs are qualified to receive a national physician identification number (NPI) that allows them to bill separately for their services. PAs are trained in general medicine, while RAs' training focuses on radiology. Nonetheless, PAs also are supervised by a physician, within the state-established limits. PAs may not function in a supervisory capacity; however, they may perform diagnostic tests under their own statutory benefits and state requirements for physician supervision. ().
A: No, the Supervision Rule does not pertain to the hospital setting (inpatient or outpatient), since Medicare reimburses for the technical component of hospital services directly to hospitals.
In the hospital setting, radiology procedure performance is governed by the Conditions of Participation, which specify that procedures should be performed based on:
However, although the Supervision Rule does not apply in the hospital setting, Medicare's payment policy (Medicare Claims Processing Manual, Chapter 13, 80.1) specifies that if the physician is not present for the supervision portion of an S&I code, which requires personal supervision, a 52 modifier (reduced services) must be appended to the procedure code to reflect that only interpretation is provided.
In the office and independent diagnostic testing facility (IDTF) settings, the Supervision Rule applies to the performance of diagnostic radiology procedures. Medicare will reimburse studies performed in the nonhospital setting under the Medicare physician fee schedule, when the requirements of the Supervision Rule are met.
A: Medicare's Supervision Rule applies to the technical component of the diagnostic tests performed in office or freestanding settings. There are three levels of physician supervision required for diagnostic tests as outlined in :
General supervision: The procedure is furnished under the physician's overall direction and control, but the physician's presence is not required during the procedure. Under general supervision, the physician is responsible for training nonphysician personnel, such as an RA, who performs diagnostic procedures and for maintaining necessary equipment and supplies.
Direct supervision: The physician must be present in the office suite and immediately available to assist and direct throughout the procedure. This does not mean that the physician must be present in the room when the procedure is performed.
Personal supervision: A physician must be in the room during the procedure.
Refer to the for a copy of the 2007 Medicare Physician Fee Schedule, which lists the current procedures and assigned supervision levels.
A: Yes, any radiology practice located in the following states should carefully examine state statutes and regulations that control RAs' scope of practice: Arkansas; Florida; Iowa; Mississippi; Montana; New Mexico; New York; Oregon; Tennessee and Wyoming.
Because the states regulate, through licensing, the practice scope, supervision requirements, and medical liability of nonphysician practitioners, the 黑料网 advises that radiology practices consult with qualified local counsel for guidance on their state’s legislation and regulations.
Please look for a future J黑料网 article for more detail and an update on the role of RAs.
Reference:
ACR Bulletin, NOV, 2001, "Clarification Given by CMS on Ordering Diagnostic Tests Rule, Supervision Rule and ICD-9 Coding Guidelines."
ACR Bulletin, June, 2001, "New Supervision Regulations Effective July 1, 2001"
, July 16, 2001.
CMS Web site Listing of at RVU07A2 - Updated 12/04/06 [ZIP 3MB]
Program Memorandum Carriers ()
The Medicare Carrier Manual, Section 15022(E)(1)