HCFA Publishes Supervision Requirements!
Frank West, BSN RN RVT FSVU, cochair, SVT Government Relations Committee

04.19.01—HCFA has finally published the supervision requirements as required under 42 CFR 410.32 (Federal Register, 10/31/97) and as required by Phase I of the "Stark II" Final Rules for the in-office ancillary services exception (Federal Register, 1/4/01). We have been waiting to see what these were going to look like for three years.

Overall, secondary to efforts (and, over three years, hundreds of thousands of dollars) by SVT, SDMS, SVS, ASN, AAN, and a host of other specialty associations, as well as incredible support provided by SVT's membership, most of the requirements for direct or personal supervision for ultrasound procedures (as published in the 10/31/97 Federal Register) have been altered
to those suggested by the multi-specialty alliance at the June, 1998 HCFA meeting (as well as numerous other meetings SVT has attended).

Specifically, ALL noninvasive vascular CPT codes 93875 through 93990 require general supervision. However, 76936 (Ultrasound guided compression repair of arterial pseudo-aneurysm or arteriovenous fistulae (includes diagnostic
ultrasound evaluation, compression of lesion and imaging) requires PERSONAL supervision, meaning a physician must be in attendance in the room during the performance of the procedure. This represents the single exception to SVT's original set of recommendations for vascular procedures.

As of 7/1/01 (implementation date of the PM - and barring revision or delayed implementation), the following procedures will require direct supervision in the office setting (i.e., Part B - physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician must be present in the room when the procedure is
performed.):

• 76506 Echoencephalography, B-scan and/or real time with image documentation (gray scale) (for determination of ventricular size, delineation of cerebral contents and detection of fluid masses or other intracranial abnormalities), including A-mode encephalography as secondary component where indicated
• 76516 Ophthalmic biometry by ultrasound echography, A-scan;
• 76519 with intraocular lens power calculation
• 76529 Ophthalmic ultrasonic foreign body localization
• 76800 Echography, spinal canal and contents
• 76805 Echography, pregnant uterus, B-scan and/or real time with image documentation; complete (complete fetal and maternal evaluation)
• 76810 complete (complete fetal and maternal evaluation), multiple gestation, after the first trimester
• 76815 limited (fetal size, heart beat, placental location, fetal
  position, or emergency in the delivery room)
• 76825 Echocardiography, fetal, cardiovascular system, real time with image documentation (2D) with or without M-mode recording
• 76885 Echography of infant hips, real time with imaging documentation; dynamic (eg, requiring manipulation)

The following procedures will require personal supervision (physician must be in attendance in the room during the performance of the procedure):

• 75611
• 76512
• 76513
• 76831
• 76930-76965 inclusive (ALL ultrasound guidance procedures)
• 76975
• 76986
• 93312
• 93313
• 93314
• 93315
• 93316
• 93317