CMS will begin reinforcement of supervision requirements at CAHs

Hospitals are required to ensure that a physician or qualified non-physician provider provides direct supervision of outpatient therapeutic services, including chemotherapy administration and radiation therapy.

Although Critical Access Hospitals (CAHs) were encouraged to comply with the regulation, for the past several years CMS indicated that it would not enforce the requirements for small rural hospitals. In 2014, CAHs will be expected to be in compliance with all supervision requirements in order to be eligible for Medicare reimbursement.

Complying with the supervision requirement is resource intensive. Prior to 2010, most hospitals assumed that simply locating their outpatient departments on the hospital’s campus, where physicians were working at all hours, was sufficient to meet CMS’s supervision requirements.

Following the “clarification” CMS issued in 2010, many hospitals had to hire additional physicians or advanced practice providers to ensure that a qualified clinician was available to supervise care in infusion and radiation therapy centers.

CAHs are now concerned that the enforcement of the supervision requirements will force them to close outpatient departments, including infusion centers, thus making it more difficult for their patients to access care.