another general supervision question

[BobbyHeenan]

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We've talked extensively about using an NP or PA to supervise a single linac hospital based clinic maybe 1-2 days....but let's say only an RN is in the clinic. No designated mid level is there.

So hospital based, only an RN there, and physician available by phone but not immediately available.

Can you treat standard fractionation (no SBRT, CT sim, HDR) per new CMS rules in this scenario?

Our group feels best patient care would be for MD to be there, but if no MD then a mid level. But what about above?

 

[elementaryschooleconomics]

I think this is explicitly what the 2020 HOPPS rule permits.

You're proposing:

1) hospital outpatient therapeutic services provided by a hospital

2) physician or advanced practitioner must be available by telephone to provide assistance and direction if needed

There doesn't appear to be any further stipulations. Unless you're APEx accredited or following some other certification/designation which requires/promotes direct supervision, there's nothing stopping you or any other hospital group from pursuing this model.