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) where allowed by state regulations. 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.
With respect to these recent changes under the 2019 MPFS, AHRA’s Regulatory Affairs Committee sought to survey radiology professionals to better understand how Radiology Assistants are being used in Radiology operations.
Of the roughly 300 individuals surveyed, 26% currently use RAs in their operation while roughly 74% do not. It appears more than half of RAs working in the field are employed by the Radiology group, with the remainder being employed by the hospital or organization.
Staffing or allocating full time equivalents (FTE) for RAs was the most commonly found to be 1 FTE (40%), whereas 23% of respondents reported using 2 FTEs. Conversely, many organizations that use RAs allocate less than 1 FTE for this position (16%). Employing 3 or more FTEs was also reported at roughly 10% respectively.
Fluoroscopic procedures followed by invasive procedures such as arthrograms, fluid drainage, biopsies, etc. are the most common duties performed by RAs at 79% and 66% reported respectively. Other procedures performed (in descending order) included: GU procedures (IVPs, antegrade urography, nephrostogram, etc.); providing a report to the radiologist; administering medications as prescribed by a radiologist; and urinary catheterization.
About 19% of RAs in the field currently work in freestanding imaging centers and only about 4% work in private offices. The vast majority are found in hospitals, in both inpatient and outpatient settings.
With respect to billing for RA services, about 40% of survey respondents reported that billing is through the Radiologist billing office, while 35% say their hospital or organization bills for these services. The remainder of respondents suggested a professional/technical split between the Radiologist’s and the hospital, while some respondents (13%) were unsure of the billing method.
When asked if the recent changes in supervision requirements from “personal” to “direct” would expand their use of radiology assistants, 45% believed it would. 14% thought the RA scope would not change and roughly 40% were not yet sure.
We asked if more RAs would be hired or used if the scope of services for RAs were to be expanded to include more interventional services (under MARCA H.R. 1970). More than 50% of respondents were not yet sure, while 40% believed they would likely employ more RAs and 13% felt nothing would likely change.
If you have questions about the changes to the CMS supervision requirements for Radiology Assistants, or other regulatory topics, please contact the Regulatory Affairs Committee at email@example.com. Or, post a comment below. You can find the raw survey data here.
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 firstname.lastname@example.org.