By Sheila M. Sferrella, MAS, RT(R), CRA, FAHRA
The Centers for Medicare & Medicaid Services (CMS) finalized a regulatory revision in the 2019 Medicare Physician Fee Schedule (MPFS) final rule, effective January 1, 2019, that changes supervision requirements for Radiology Assistants (RAs). CMS recognizes both Registered Radiologist Assistants (RRAs), who are certified by The American Registry of Radiologic Technologists (ARRT), and Radiology Practitioner Assistants (RPAs), who are certified by the Certification Board for and Radiology Practitioner Assistants (CBRPA) as RAs. These RAs, also known as physician extenders, perform patient assessment, patient management, fluoroscopy, and other radiology procedures. The changes outlined in the MPFS, reduce the level of supervision necessary to perform certain diagnostic tests performed by Radiology Assistants, and reimbursable by Medicare.
CMS defines levels of supervision as “general,” “direct,” and “personal.” Personal supervision requires the supervising physician to be in the same room during the performance of the procedure, whereas direct supervision requires the supervising physician to be present in the same office suite or area and “immediately available” to provide assistance and/or direction during the performance of the procedure. General supervision requires a physician to maintain “overall direction and control” over a procedure, but the physician is not required to be physically present, or immediately available (ie may be in a remote location) during the actual performance of the procedure. Procedures falling within the general supervision category are typically those performed routinely by technologists whereas gastrointestinal (GI) and genitourinary (GI) procedures will require either direct or personal supervision for the RA. The supervision level required for diagnostic services is assigned by CMS and searchable in the CMS Medicare Physician Fee Schedule Database.
With this update, RAs may now perform diagnostic tests that would previously require a personal level of supervision to be performed under direct supervision; to the extent allowable by state law. There were no changes to procedures that currently require general supervision by a physician. Not all states recognize Radiology Assistants equally, and many have specific supervision requirements in place for Radiology Assistants. According to the Society of Radiology Physician Extenders, there are 31 states which recognize and/or license RAs.
In the coming weeks AHRA’s Regulatory Affairs Committee will distribute a survey to members on the utilization of Radiology Assistants. Please take a few moments to complete this brief survey, as your feedback is vital in helping us to understand our current environment and provide you with important industry information to better manage operations. We also use your feedback in the comment letters we send to CMS.
If you have questions about the changes to the CMS supervision requirements for Radiology Assistants, or on other regulatory topics, please contact the Regulatory Affairs Committee at firstname.lastname@example.org.
Sheila M. Sferrella, MAS, RT(R), CRA, FAHRA is the chair of the AHRA Regulatory Affairs Committee. She is the president of Regents Health Resources in Brentwood, TN and can be reached at email@example.com.