October 20, 2021
PAs Authorized to Supervise Clinical Staff Performing Diagnostic Tests for Medicare Beneficiaries
December 2, 2020
By Michael Powe, Vice President of Reimbursement & Professional Advocacy
As part of the final 2021 Physician Fee Schedule, the Centers for Medicare and Medicaid Services (CMS) permanently authorized PAs to supervise clinical staff who perform diagnostic tests for Medicare beneficiaries. Formerly, only physicians had been granted this supervisory authority. PAs already had the authority to personally perform all diagnostic test in accordance with state law.
A COVID-19 Public Health Emergency (PHE) waiver gave PAs temporary authority to supervise diagnostic test, but that authorization will expire when the PHE ends.
Under the new rule, effective January 1, 2021, PAs will be able to engage in other clinical responsibilities while simultaneously providing supervision for clinical staff who perform diagnostic tests that don’t require the personal presence of a PA or physician.
Billing Pharmacists Services Incident to a PA
The agency clarified that pharmacists, similar to other clinical staff, may provide services incident to and under the appropriate level of supervision of the billing physician, PA, or advanced practice nurse. This type of incident to billing scenario, as authorized by state law, would be more likely to occur with pharmacists who provide medication management services to Medicare beneficiaries.
While adding a number of additional services that can be provided via telehealth, CMS stated it does not have the statutory authority to authorize permanent payment for telehealth delivered in non-rural areas or for any patients located in their homes. COVID-19 PHE waivers currently allow Medicare coverage for telehealth services in urban areas and for beneficiaries in their homes.
CMS will not reimburse for audio-only telephone E/M services after the PHE ends. The agency proposes to create a new virtual check-in code for longer conversations.
Office E/M Documentation
CMS also confirmed that Evaluation and Management documentation guidelines for office services will be based on either medical decision-making or time. Recording the history and exam are still necessary components for the medical record but will not be used to determine the visit level code submitted for reimbursement.
AAPA will provide a more in-depth review of the 2021 Physician Fee Schedule Rule in the near future.