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Supervision Requirements for Diagnostic Tests

On March 16, 2023, Medicare issued MLN Matters - MM13094 which clarified language related to the January 1, 2021 rule that expanded the list of providers who can supervise diagnostic tests to include Nurse Practitioners (NPs), Clinical Nurse Specialists (CNSs), Certified Nurse-Midwives (CNMs), Certified Registered Nurse Anesthetists (CRNAs) and Physician Assistants (PAs). The rule clarifies that “when NPs, CNSs, and PAs personally perform diagnostic tests as provided under Section 1861(s)(2)(K) of the Act, the supervision/collaboration requirements under Section 1861(s)(3) of the Act and 42 CFR 410.32 don’t apply. Rather, these practitioners are authorized to personally perform diagnostic tests under the supervision/collaboration requirements applicable to their practitioner benefit category pursuant to state scope of practice laws and under the applicable state requirements.” These services should be billed to Medicare under the practitioner’s own provider number and may not be billed as “incident to.” 

MM13094 may be found here.

About The Author

Jackie Boswell is an Assistant Vice President in SVMIC’s Medical Practice Services Department. Her background includes over 25 years as a medical management executive including hospital and physician practice administration. She obtained a Bachelor’s degree in Computer Information Systems from Murray State University and a Masters Degree in Business Administration from Belmont University. She is a Fellow in the American College of Medical Practice Executives and has served as Finance Chair for MGMA’s Financial Management Society and as the ACMPE Forum Rep for the Tennessee MGMA. Jackie is a member of the Board of Directors and Finance Committee at Three Rivers Hospital in Waverly, TN. She also serves on the United Way Allocations Committee in Humphreys County. 

The contents of The Sentinel are intended for educational/informational purposes only and do not constitute legal advice. Policyholders are urged to consult with their personal attorney for legal advice, as specific legal requirements may vary from state to state and/or change over time.

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