The American Hospital Association (AHA) feels that hospitals that struggle with maintaining adequate staffing have difficulty meeting specific physician supervision requirements. 
Basically, The Centers for Medicare & Medicaid Services (CMS) requires physicians be “immediately available” to provide direction and assistance throughout the performance of certain procedures when performed by non-physician providers. However, the American Hospital Association feels that 28 of the procedures on the list do not require such a high level of supervision and asked CMS to decrease the requirement to general supervision. General supervision procedures can be furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. CMS agreed with the AHA on 15 procedures, including intravenous (IV) hydration infusion, and downgraded them to general supervision. However, CMS maintained that there is clinical justification for requiring direct supervision requirement for the other 13 procedures, which include drug injections, H1N1 vaccinations, and application of compression systems. AHA Executive Vice President Rick Pollack disagrees. In a letter to CMS, he wrote “There is little or no research available that evaluates the clinical implications of direct versus general supervision of outpatient services, especially as it relates to specific services covered under the outpatient PPS.” Furthermore, the AHA argued that small, rural hospitals and critical access hospitals, who struggle with maintaining adequate staffing levels, will have difficulty meeting the requirements, which could limit the services available to patients in those areas. The AHA asks that CMS reconsider its approach to assigning level of supervision to those 13 procedures.
Basically, The Centers for Medicare & Medicaid Services (CMS) requires physicians be “immediately available” to provide direction and assistance throughout the performance of certain procedures when performed by non-physician providers. However, the American Hospital Association feels that 28 of the procedures on the list do not require such a high level of supervision and asked CMS to decrease the requirement to general supervision. General supervision procedures can be furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. CMS agreed with the AHA on 15 procedures, including intravenous (IV) hydration infusion, and downgraded them to general supervision. However, CMS maintained that there is clinical justification for requiring direct supervision requirement for the other 13 procedures, which include drug injections, H1N1 vaccinations, and application of compression systems. AHA Executive Vice President Rick Pollack disagrees. In a letter to CMS, he wrote “There is little or no research available that evaluates the clinical implications of direct versus general supervision of outpatient services, especially as it relates to specific services covered under the outpatient PPS.” Furthermore, the AHA argued that small, rural hospitals and critical access hospitals, who struggle with maintaining adequate staffing levels, will have difficulty meeting the requirements, which could limit the services available to patients in those areas. The AHA asks that CMS reconsider its approach to assigning level of supervision to those 13 procedures.
