Medicare Finalizes Favorable Change in Diagnostic Testing Rule
by Government Relations Staff
November 23, 2004 -- The Centers for Medicare and Medicaid Services (CMS), the federal agency that administers the Medicare program, has finalized a revision to its diagnostic testing rule allowing clinical psychologists to supervise ancillary staff such as technicians in doing psychological and neuropsychological testing. Under the current rule, only physicians have been authorized to supervise such testing.
The decision was announced in November as part of the final rule on the 2005 physician fee schedule. The rule change takes effect on January 1.
As the Practice Organization had advocated, the rule allows psychologists to provide general supervision for psychological and neuropsychological testing. This decision means that the testing is conducted under the psychologist’s overall direction and control, but the psychologist’s presence is not required during the testing. General supervision is the same level required of physicians when they supervise such testing.
Expanding the testing rule has been a regulatory priority for the APA Practice Organization, and we have actively sought the rule change for more than two years. In issuing its revised rule, CMS noted the Practice Organization’s rationale in support of the change.
To learn more about the rationale for the rule change, view the document on the CMS website and see the related discussion on pages 601- 604 and 779-780.
The “incident to” factor
Significantly, the rule change acknowledges the role that psychologists play in testing as well as their ability to supervise others engaged in diagnostic testing. However, the change does not alter the existing conditions that must be met for reimbursement when outpatient testing services are provided “incident to” the services of a psychologist.
According to Medicare rules, psychologists seeking reimbursement for services provided by ancillary staff “incident to” the psychologist’s services must engage in direct supervision of that staff. The direct supervision requirement means that the psychologist must be present in the office suite and immediately available to furnish assistance and direction as the service is being performed.
In essence, psychologists who supervise ancillary personnel providing “incident to” services still need to comply with all “incident to” requirements imposed by Medicare as a condition of reimbursement. Psychologists should check with the Medicare carrier in their geographic area for information on local policies that apply to “incident to” services.
Download_Diagnostic_Testing_article.pdf
(72.26 Kb)
