I apologize in advance for the "stream of consciousness" and "preaching to
the choir" ...

Given your reference is to the 10/31/97 Federal Register (Final Rule -
physician's fee schedule), implementation of the supervision portion of this
rule was indefinitely postponed in January 1998 due to the concerns we
expressed and pending revisions.  The most recent NPRM for 2000 confirms
HCFA's intent to implement the rule but does not provide any statement
regarding the requisite levels of supervision.  However, based on
discussions with HCFA employees, a Program Memorandum has been approved and
is awaiting release that will, for the non-invasive vascular CPT codes, set
the requisite level of supervision as "general" as defined in the 10/31/97
FR (i.e., the physician does not have to be present, either in the room
[personal] or in the suite [direct] during the procedure).  In my opinion,
this is the result of an enormous amount of work on the part of SVT,
SVS/ISCVS, SDMS, ARDMS and other professional organizations (or, more
precisely, the members) and is one of the clearest examples of what
individuals can accomplish when we work as one.  (another clear example was
the avoidance of the enormous decreases in reimbursement that were scheduled
to take place this year based on the flawed practice expense model)

If your reference is to the Notice of Proposed Rule Making for Stark II (FR
1/9/98), we have been informed that the group working on this issue at HCFA
is not inclined to alter their requirement for direct supervision as part of
the in-office ancillary services exemption.  Both Rep. Stark and Rep. Thomas
have submitted amendments to the statute that would address this issue but
these are only bills (HB 2650 & 2651 if memory serves) and are a long way
from becoming law (and they do not address all the issues we have with the
Stark II NPRM).  It is my understanding that SVT (based on input from Bill
Sarraille) is currently determining the best mechanism to deal with this
issue but this may well require financial support.  It is my personal
opinion that this is a critical issue and, as I read the NPRM, would impact
procedures performed both in hospitals and offices for which the
interpreting physician referred the patient (i.e., I found no exception for
the TC of procedures performed in hospitals).

"The punishment of wise men who refuse to take part in the affairs of
government is to live under the government of unwise men."
- Plato

You might want to get a copy of the SVT Legislative Watch Information Kit
(800.SVT.VEIN) ... it contains some great information ...

Franklin W. West
18702 North Creek Parkway, Suite 212
Bothell, Washington   98011
425.483.4058 (voice)
425.486.8976 (fax)
[log in to unmask]

-----Original Message-----
From: [log in to unmask] [mailto:[log in to unmask]]On
Behalf Of Collins, Lonnie
Sent: Tuesday, September 07, 1999 8:58 AM
To: [log in to unmask]
Subject: Supervision
Importance: High

Can any one confirm that the HCFA issue of supervision.  I have been told
that it came out in the National Registry that all ultrasound exams will be
done under direct supervision and not general.

And what does it mean that it has been posted in the Registry,  is this law?


Lonnie Collins, RVT
Coordinator/Technical Director
Vascular Lab Services
University Hospital and Clinics
University of Missouri, Columbia
(573) 882-3020