What are the rules for when a Rad Onc has to be in the building?

[RadOnc2013]

I love my job, and I don't mind being on site through the treatment day. But there is a full gym across the street, and it'd be nice to go when my therapists are just plowing through breast treatments, I have nothing to do, and they could just call me back for issues. Anyway ... does anyone know the rules for when the Rad Onc needs to be in the building? I have med oncs seeing patients in the same building, albiet their clinic days are shorter than mine ....

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[medgator]

Physical Presence; you mean like I have to be there?

Oncology Therapy Center in High Desert Pays $3 Million to Resolve Allegations of Providing Radiation Treatments without Doctor Present

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[XRT_doc]

I love my job, and I don't mind being on site through the treatment day. But there is a full gym across the street, and it'd be nice to go when my therapists are just plowing through breast treatments, I have nothing to do, and they could just call me back for issues. Anyway ... does anyone know the rules for when the Rad Onc needs to be in the building? I have med oncs seeing patients in the same building, albiet their clinic days are shorter than mine ....

Are you in a free-standing center or in a hospital. If there are other doctors and in a hospital based center you'd be fine.

 

[seper]

In my experience, even hospital-based centers now have internal policies asking physicians to remain on-site while the beam is on.
In addition, a physician would risk losing some his/her moral standing among therapists by being away 🙂

 

[deleted18755]

In my experience, even hospital-based centers now have internal policies asking physicians to remain on-site while the beam is on.
In addition, a physician would risk losing some his/her moral standing among therapists by being away 🙂

I agree. Simply not worth the risk with regards to legal issues or “respect” I guess from staff or referring physicians.

There are already way too many physicians who think we aren’t real doctors ... I can’t imagine a referring physician swinging by to discuss a case only to realize that I’m at the gym at 10:30am while the rest of my staff are working and patients are actively under treatment.

Sooner or later they are going to need you to come back mid workout and even if all you have to do is run across the street are you really going to stand there with a ring around your collar, pitted out, in gym shorts checking a CBCT or whatever?

I understand you’d rather take an hour during the day and go home an hour later then hit the gym after work and at the end of the day it may seem like the same thing but it won’t be perceived that way.

 

[Haybrant]

I agree. Simply not worth the risk with regards to legal issues or “respect” I guess from staff or referring physicians.

There are already way too many physicians who think we aren’t real doctors ... I can’t imagine a referring physician swinging by to discuss a case only to realize that I’m at the gym at 10:30am while the rest of my staff are working and patients are actively under treatment.

Sooner or later they are going to need you to come back mid workout and even if all you have to do is run across the street are you really going to stand there with a ring around your collar, pitted out, in gym shorts checking a CBCT or whatever?

I understand you’d rather take an hour during the day and go home an hour later then hit the gym after work and at the end of the day it may seem like the same thing but it won’t be perceived that way.

Ya ultimately it’s the state of the field, this is how medicine is and so you could do stuff like that but you do risk other doctors and staff giving the wtf which ultimately erodes status even if you’re really good. It’s why people want to be entrepreneurs that create something to sustain themselves, it can be scaled and you only need to be present when things are going wrong to troubleshoot. Medicine can not be scaled and you have to be present all the time or enjoy sitting in the office w Netflix. I do think medicine needs to change though but not while the dinosaurs are around it won’t.

 

[Irradi8or]

In a freestanding setting, are any of you using a non-Rad Onc physician (i.e. Med Onc) to cover you as incident to? The more freestanding groups I ask, the more varied the answer I get. I thought that in general for a freestanding center, you need a Rad Onc for billing (and some say in particular for IGRT), but others do use a Med Onc for incident to. ASTRO position statement makes it seem like it should be Rad Onc as well. Thanks for your thoughts!

 

[medgator]

In a freestanding setting, are any of you using a non-Rad Onc physician (i.e. Med Onc) to cover you as incident to? The more freestanding groups I ask, the more varied the answer I get. I thought that in general for a freestanding center, you need a Rad Onc for billing (and some say in particular for IGRT), but others do use a Med Onc for incident to. ASTRO position statement makes it seem like it should be Rad Onc as well. Thanks for your thoughts!

I don't know anyone who isn't using an RO to cover igrt patients. ASTRO white paper/CMS guidelines suggest you need someone capable of assisting in the "procedure" of igrt.

Supposedly the hospital setting is a bit more lenient where you theoretically could document training an NP in igrt and using them to cover if needed.

Again if you ever end up in court, it may not look good, but it would still pass muster I think

 

[SneakyBooger]

Its vague. So we just have a doc in building during all treatments.

However, I believe rural rad oncs are exempt from this CMS mandate, but since this doesn't apply to me I'm not entirely sure. But who is?

 

[thecarbonionangle]

Some rad onc facilities rad oncs are not always there it seems just a med onc nearby or some warm body with an MD vs some facilities where always a rad onc is there. These are vastly different extremes. What is legal or not?

 

[Bequerel]

Some rad onc facilities rad oncs are not always there it seems just a med onc nearby or some warm body with an MD vs some facilities where always a rad onc is there. These are vastly different extremes. What is legal or not?

My understanding is that an MD “credentialed” to do so has to be present at freestanding and an MD, PA or NP “credentialed” to do so has to be present at hospital based facility

 

[KHE88]

If you read the CMS rules, it is clear as day. I don't understand why people are confused by this.

In order to bill medicare for treatment...

Center attached to a hospital: A provider must be immediately available, but it does not have to be a radiation oncologist. A different MD, PA, or APRN would qualify.

Freestanding center: A radiation oncologist must be present

Critical access hospital: The above rules are not enforced.

Now, some hospitals are not "comfortable" with this and require a radiation oncologist to be present, but that is their choice. Legally, they don't have to. It is very clear.

 

[medgator]

If you read the CMS rules, it is clear as day. I don't understand why people are confused by this.

In order to bill medicare for treatment...

Center attached to a hospital: A provider must be immediately available, but it does not have to be a radiation oncologist. A different MD, PA, or APRN would qualify.

Freestanding center: A radiation oncologist must be present

Critical access hospital: The above rules are not enforced.

Now, some hospitals are not "comfortable" with this and require a radiation oncologist to be present, but that is their choice. Legally, they don't have to. It is very clear.

Np or PA has to be able to "furnish assistance" during the procedure. Good luck documenting how you taught your NP to line up cbcts in a court of law. I'm sure it can be done, but I would seek counsel, personally...

 

[SneakyBooger]

Np or PA has to be able to "furnish assistance" during the procedure. Good luck documenting how you taught your NP to line up cbcts in a court of law. I'm sure it can be done, but I would seek counsel, personally...

I (reluctantly) agree. IMO, if they come for you, the writing is on the wall. You will be burned. Regardless of counsel. Would love to see a court case review that says otherwise, if anyone has one. Even still, I would be reluctant to not have a rad onc in building - except in rural areas.

 

[Reaganite]

If you read the CMS rules, it is clear as day. I don't understand why people are confused by this.

In order to bill medicare for treatment...

Center attached to a hospital: A provider must be immediately available, but it does not have to be a radiation oncologist. A different MD, PA, or APRN would qualify.

Freestanding center: A radiation oncologist must be present

Critical access hospital: The above rules are not enforced.

Now, some hospitals are not "comfortable" with this and require a radiation oncologist to be present, but that is their choice. Legally, they don't have to. It is very clear.

Agree, this is how CMS spells it out. That being said, Rad onc has to supervise in freestanding center where we will pay less; non-Rad Onc can supervise in hospital where we pay more. Oh yeah, and btw, supervision isn't really that important if you're in a rural area. Wait, what?

 

[evilbooyaa]

Is critical access the same as the rural exemption? I thought there was a rural exemption even for free standing that says a non rad-onc MD or NP/PA could provide machine coverage.

 

[medgator]

Is critical access the same as the rural exemption? I thought there was a rural exemption even for free standing that says a non rad-onc MD or NP/PA could provide machine coverage.

Medicare defines these entities as "critical access hospitals" or CAHs. I've never seen one in the wild, personally