SVT Writes HCFA on Supervision

June 16, 2000

Mr. Paul Kim
Health Care Financing Administration

Dear Mr. Kim:
Thank you for recently providing to Frank West of the Society of Vascular Technology and to Stacy Harbison of my firm preliminary information regarding the proposed levels of supervision in connection with the Program Memorandum that is under consideration by the Health Care Financing Administration.

On behalf of the Society of Vascular Technology (“SVT”), the Society of Diagnostic Medical Sonographers (“SDMS”), the Society of Vascular Surgery (“SVS”, the International Society for Cardiovascular Surgery (“ISCVS”), and the American Society of Neuroimaging (“ASN”), I wanted to write to you to indicate that these societies strongly support the issuance of a Program Memorandum by HCFA in order to address what appears to be on-going confusion by many carriers and intermediaries regarding appropriate levels of supervision for diagnostic services. We very much appreciate the opportunity to comment on the proposed levels of supervision, and would be happy to assist HCFA in any manner we can. Our understanding is that the Program Memorandum calls for non-contrast ultrasound, MRI, and CT services to continue to be provided under general supervision, as is the present standard of practice, unless some specific reason for a higher level of supervision is shown.

SVT is a multidisciplinary professional society, with both physician and technologist and other allied health members. Founded in 1977 by a handful of dedicated technologists, SVT now has more than 4,000 members, united in their dedication to the advancement of noninvasive vascular technology and to their commitment to achieve excellence in patient care.

SDMS, which represents general and cardiac sonographers and vascular technologists, has a membership of 11,000. SDMS members are involved in the delivery of high-quality echocardiography, obstetrical, abdominal and ophthalmic ultrasound, and vascular ultrasound services.
SVS and ISCVS are professional societies that include approximately 1,600 vascular surgeons who practice across the United States. SVS and ISCVS have a shared mission to advocate for quality care and access to vascular services.

ASN is an international, professional organization representing neurologists, neurosurgeons, neuroradiologists, and other neuroscientists who are dedicated to the advancement of any technique used to image the nervous system. Its purpose is to promote the highest standards of neuroimaging in clinical practice, thereby furthering ongoing improvement in the delivery of medical care.

SVT, SDMS, SVS, ISCVS, and ASN strongly support the proposed levels of supervision for the ultrasound services and the CT and MRI services for which you supplied information. We believe that the information regarding the levels of supervision that you indicated are under consideration are the appropriate levels of supervision and reflective of the standard of care observed by providers across the country.

We have only one suggested change which has to do with the proposed level of supervision for MRA services of the head. In considering this issue, John B. Chawluk, M.D., the incoming President of ASN, made the following observation: Head MRA, which is typically performed without contrast injection, should be a general supervision procedure. We see no basis to distinguish 72149 from 72158 and 72148 (the Lumbar MRI procedure codes). If 72149 does not involve an injection of intravenous contrast agent, then general supervision is appropriate.

We would be very grateful if HCFA would consider this comment as it prepares to finalize the Program Memorandum. If the proposed levels for any of our members’ services change from what was related to us, we would appreciate an opportunity to comment further before the Program Memorandum is issued.

Again, each of the societies we represent wanted to express their tremendous appreciation for the work that HCFA has done in connection with the Program Memorandum. We are grateful that HCFA is undertaking this task.

Please let me know if we can supply you with any additional information.

Very truly yours,
William A. Sarraille
Arent Fox