An example of a service assigned this supervision requirement is 92640 Diagnostic analysis with programming of auditory brainstem implant, per hour. 3 Procedure must be performed under personal supervision On December 1, 2020, the Centers for Medicare and Medicaid Services (CMS) released its Medicare Physician Fee Schedule (PFS), The Advocacy Council recently learned of a number of payer audits and recoupment requests related to Xolair billing -, The Advocacy Council recentlysubmitted commentsto the Centers for Medicare & Medicaid Services (CMS) about a proposedAsthma/COPD cost measurein the, 2023 American College of Allergy, Asthma & Immunology | Policies | Terms of Use | Built by Social Driver. 0000004878 00000 n Similarly, if an NP or PA is supervising auxiliary staff who are performing services incident to the NPs or PAs service (and this supervision is allowed under their state license), those services must be billed under the NPI of the NP or PA. A 0 indicator (procedure is not a diagnostic test, or procedure is a diagnostic test not subject to the physician supervision policy) currently is not assigned to any CPT or HCPCS Level II code in the Relative Value File. Provider Resource Center Click A 22 indicator (procedure may be performed by a technician with on-line real-time contact with physician) currently is not assigned to any CPT or HCPCS Level II code in the Relative Value File. The service is reported under the APP's NPI number. We also use third-party cookies that help us analyze and understand how you use this website. Our PAs practice with supervision. In order to qualify as incident to services the following criteria must be met: The type of site you are operating in matters with respect to whether these services are allowed: Providers eligible to provide psychological services incident-to: None physician practitioners can provide certain services in the place of physician practitioners (Medicare providers), and bill under the Medicare providers NPI number. Can a provisionally licensed person bill under a supervisors license. 0000001773 00000 n `40P cY< Scroll down to Referrer section. Do they see only follow up patients and cover allergy shots, and is there always an allergist in the clinic with them? B. Policy on Cooperative Programs With Industry, Medicare finalizes complexity add-on code G2211 for 2021, New CMS MIPS cost measure will impact allergists. Populate Box 17: Name of Referring Provider or Other Source. Check your states licensing and scope of practice regulations to identify other requirements. acting under the supervision of a physician or Advanced Practice Health Care Provider, regardless of whether the . 5X^32X-Oa5zF`eD.( FwrdXya5zCdTaT:l6 5 x Additionally, the part of incident-to services and billing that comes up most frequently for mental health professionals is when services are supervised by certain non-physician practitioners. LLPCs must work under an LPC . endstream It is best to contact each individual panel to determine if incident-to billing or supervised services are allowed under the plan. under the ownership, financial, and administrative control of the hospital or CAH; operated as part of the hospital or CAH; and. CMS guidelines specify, "Documentation maintained by the billing provider must be able to demonstrate that the required physician supervision is furnished." The guidelines do not provide examples of appropriate documentation; however, for those services requiring personal supervision, the physician should document, with a comment and . Such services are identified in the Relative Value File with the following indicators: If so, incident to billing might work. 77 Procedure must be performed by a PT with ABPTS certification, or by a PT without certification under direct supervision of a physician, or by a technician with certification under a physicians general supervision. endobj <> G A+}`q6LQA6. Blue Cross Blue Shield of WyomingServing residents and businesses in Wyoming. Services meeting all of the above requirements may be billed under the supervising physician's NPI, as if the physician personally performed the service. The services must be part of your patients normal course of treatment, during which a provider personally performed an initial service and remains actively involved in the course of treatment. Medicare: Medicare Reimbursement Claims for services are submitted on the 1500 Claim Form. 422 0 obj <>/Filter/FlateDecode/ID[<654FEC9A3EB63646944749AEF33BC57C>]/Index[401 51]/Info 400 0 R/Length 108/Prev 177455/Root 402 0 R/Size 452/Type/XRef/W[1 3 1]>>stream V`Br\ j`y~ Note: The provider does not have to be physically present in the patients room while the services are performed but you must provide direct supervision. 451 0 obj <>stream Direct Billing Under direct billing, the APP provides the entire service in any setting, including the office and hospital. I have a supervising provider that is following NPs and PAs under his supervision. Modifiers AJ, AH, AM, HA and GF are also eligible modifiers for professional services and can be reported in addition to modifier SA. This question comes up A LOT. This policy sets forth the requirements for (i) reporting the services provided as "incident-to" a Supervising Health Care Provider in the office or clinic setting and (ii) reporting Split and/or shared evaluation and management services in a facility setting. The allergist must actively participate in and manage the patients treatment. 0 y7XS/W[Ba-XS/57;Qk2A? Further clarification: Only licensed mental health clinicians may provide supervision to a non-licensed rostered mental health clinician for purposes of supervised billing and sign-off on IPCs. As outlined in the 2010 Hospital OPPS Final Rule, All hospital outpatient services that are not diagnostic are services that aid the physician in the treatment of the patient, and are called therapeutic services. Supervision requirements for outpatient hospital therapeutic services are different than those for outpatient diagnostic services. For some services, supervision requirements depend on the training of the provider administering the service. 282 0 obj <>stream 4Dg+u3IKN?iS1P>'5AO*$Z+x~uj +58O+ ' gXQ #0 7[D'N(53 0 This type of billing is used when an NPP sees a patient in which the physician has performed the initial service and has initiated a Plan of Care or treatment plan. FURTHER GUIDANCE ON INCIDENT TO BILLING . endobj {"AdE6do I have had multiple people tell me different things. As far as billing supervised services, Medicare regulations are fairly straightforward: Physicians need to add a -GC modifier to the CPT code they're billing for. x]n0Bo`.E@KzEd <> CMS recognizes three primary levels of physician supervision. Incident-to services are defined as services that incident to physician or adjunctive to provider rendered services. Included in this category is the technical component of many urinary studies, such as 51792 Stimulus evoked response (eg, measurement of bulbocavernosus reflex latency time). 31 0 obj VERDICT: Jury Convicts City of Philadelphia Employee of Billing Medicaid Providers for Work He Did Not Perform . the BHS billing guideS under the . Medicare supervision requirements apply to outpatient services in both the hospital setting and the physician office. 1. Resource: The Medicare National Physician Fee Schedule Relative Value File is available as a free download on the CMS website: www.cms.gov/PhysicianFeeSched/PFSRVF/list.asp?listpage=4. These cookies do not store any personal information. Policy on Cooperative Programs With Industry. endobj For inpatient services, the Centers for Medicare & Medicaid Services (CMS) defers to hospital policy and Joint Commission on Accreditation of Healthcare Organizations (JCAHO) standards. endobj endstream endobj 380 0 obj <. endobj Example: For PAs, we can bill them as the supervising provider because the MD accepts responsibility for the PA and their billing. Many commercial payers have begun to require that services performed by mid-level practitioners [e.g., nurse practitioners (NPs) or physician assistants (PAs)] be billed under the National Provider Identifier (NPI) number of the practitioner and not that of the supervising physician. x]n0D%)KJ@Cxm9C9;6=0J2Q/_^}8?n~q}vR|;Mu } mz93m4c^I=k;mo)8qY?jI6BRBRmi!n~h!cIetsI2-$][H*XutV%y]7sJJJ`UV`UfW*yG> Document for Success trailer Regardless of location, if a physician personally provides the entire service, supervision requirements are not a concern. 0000012554 00000 n %%EOF hb```B ea`ZpC X=\'[-)*:X;:T+::J3H8X$Aq %LqLS60}CnH~)l Direct supervision: The meaning of direct supervision varies according to the precise location at which the service is provided: In any case, the physician does not need to be present in the room during the procedure, but must not be performing another procedure that cannot be interrupted, and must not be so far away that he or she could not provide timely assistance. (Licensed Physician Assistants)? 393 0 obj <>/Filter/FlateDecode/ID[<0ED794AB0E6FFD4E838B84E2D0C60CAE>]/Index[379 26]/Info 378 0 R/Length 75/Prev 58262/Root 380 0 R/Size 405/Type/XRef/W[1 2 1]>>stream 0000005072 00000 n 37 0 obj endobj endobj endobj 35 0 obj 0000000016 00000 n 0000001880 00000 n Medicare provides two billing options for services provided by APPs: Most commercial payers follow Medicares incident to rules. For example, a Licensed Clinical Social Worker may not hire a Nurse Practitioner and bill for the NPs medical services under the incident to provision, because a medical service by an NP is not integral to a social workers personal professional services, and is not regularly included in the SWs bill, and is outside of the SWs scope of service to provide medical services. We use cookies on our website to give you the most relevant experience by remembering your preferences and repeat visits. %PDF-1.4 % He is an alumnus of York College of Pennsylvania and Clemson University. Some commercial plans have less restrictive rules regarding incident to billing but make sure you get them in writing. 0000001366 00000 n Reimbursement is higher, but you must meet the following requirements: The allergist must perform the initial service and initiate any changes in the care plan. 26 0 obj 25 37 Any cookies that may not be particularly necessary for the website to function and is used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. But opting out of some of these cookies may have an effect on your browsing experience. The most common indicators are: An approved NPP may provide direct supervision for the service, as long as the NPP legitimately may perform the service him- or herself. 0000004237 00000 n The physician must order the diagnostic test and is responsible for training staff performing the tests, as well as maintaining the testing equipment. If youre among them, youll want to make sure youre billing for them correctly and maximizing potential revenue for your practice. 0000016042 00000 n endstream endobj startxref Mastering Insurance for Mental Health professionals, An integral part of the patients treatment course, Commonly rendered without charge (included in your physicians bills), Of a type commonly provided in a physician office or clinic (not in an institutional setting), Ordered by provider with treatment plan and notes signed by supervising physician, The service must occur and be performed by a provider whom you directly supervise and who represents a direct financial cost to you (such as W-2, leased employee or independent contractor). Reporting "Incident-to" Services As a contributor you will produce quality content for the business of healthcare, taking the Knowledge Center forward with your knowhow and expertise. endobj It is mandatory to procure user consent prior to running these cookies on your website. 43 0 obj 0000002490 00000 n March 4, 2022 Billing Under Supervising Provider Policy & Online Prior Authorization Tool Billing Under Supervising Provider Policy BCBSWY does not permit credentialed physicians to submit claims on behalf of other noncredentialed or non-physician practitioners (NPPs). The services provided must be under the scope of practice of the rendering providerANDthe supervision provider. 1 Procedure must be performed under general supervision Response: The policy allows for any behavioral health provider enrolled in Medicaid and supervising within their scope of practice to provide supervision. Disclaimer 3 5FY registered for member area and forum access, https://www.aapa.org/wp-content/uplrector-Page-Redesign-Reimbursement-101-v2.pdf. In another practice with several APPs, all of them bill under their own NPIs. hb```|eaX(m l.ls[ s6B) 4Ta! Fee Schedule Lists Supervision Requirements per Code x]1n0EwB70H\%Cd The downside is a reduction in reimbursement. endstream endobj startxref The attending provider who orders the service and provides the treatment plan must see the patient first, but not on every occurrence/visit. You asked how to indicate who the supervising provider was, and that goes in box 17. %%EOF endobj Earn CEUs and the respect of your peers. Direct supervision must be furnished by a doctor of medicine or osteopathy; non-physician practitioner cannot provide supervision. October is Eczema Awareness Month and its a great time to promote your expertise in treating this condition. Billing for services provided by an SLPA, CF, or another clinician who is not independently enrolled as a Medicaid provider may be limited. Documentation should detail who performed the service, and that a supervision physician was in the office suite at the time of the service. 2 Procedure must be performed under direct supervision Enter Supervisors NPI. Copyright 2023, AAPC 30 0 obj By clicking Accept, you consent to the use of ALL the cookies. Is this required to do it this way? But plans vary, so check your contracts to review the rules for incident to billing. Can the provider bill under supervision? 0000002714 00000 n Medicare routinely allows incident-to billing services. 36 0 obj endobj Home Office4000 House Ave.Cheyenne, WY 82001800-442-2376TDD 800-696-4710, Anesthesia Reimbursement Updates Effective 4/1/2023, we have updated our pricing on 01967 to allow eight additional units above the base instead of the previous, Hearing Aid Submission Effective 7/1/2023, BCBSWY will reimburse hearing aids at 100% of submitted invoices. 44 0 obj 0000065683 00000 n NPPs who are eligible to receive their own National Provider Identification (NPI) and who are credentialed must submit their claims directly to BCBSWY under their own NPI. This category only includes cookies that ensures basic functionalities and security features of the website. Provider Status May Affect Supervision Level Incident-to requirements are not applicable to diagnostic testing in the office setting. 0000016270 00000 n The NPI of the Medicare recognized provider (i.e. <> AAPA members pay $25. C. Provider Education: A provider education article related to this instruction will be >@f"% ff`Xy H pQ*h Click Bill To & Insurance in side menu. 29 0 obj 0000003246 00000 n endstream endobj 251 0 obj <. UnitedHealthcare will consider reimbursement for medical services rendered by Advanced Practice Health Care Providers, under the following circumstances: The service is a covered service under the member's benefit plan, . <>stream He or she does not need to be present in the room during the procedure. <>stream 2361 0 obj <>stream With incident to billing, the physician bills and collects 100% of Medicare's allowable reimbursement. However, if your APPs cover remote locations by themselves, or regularly see new patients, billing incident to wont work. endstream endobj 402 0 obj <. wV;qN3*UX These cookies do not store any personal information. =S}'q/;"H@ supervising physician. -The supervising provider (satisfying the present in-office suite/immediately available requirements) need not be the same provider who ordered the incident to services. 6a Supervision standards for level 66 apply; in addition, the PT with ABPTS certification may supervise another PT, but only the PT with ABPTS certification may bill. 33 0 obj 0000001036 00000 n Resource: Medicare physician supervision requirements for outpatient diagnostic services are defined by CMS Program Memorandum B-01-28, change request (CR) 850 (April 19, 2001), and may be found in Medicares Internet Only Manual, 100-02 Medicare Benefit Policy Manual, chapter 15, 80. 0000017971 00000 n 39 0 obj Would you rather our team handle your credentialing needs? In either case, the supervising provider does not need to be present in the room during the procedure, but must not be performing another procedure that cannot be interrupted, and must not be so far away that he or she could not provide timely assistance. First, lets make sure we have common language as we discuss this topic. L#XCX#$|4la0a ,^yL, 404 0 obj <>stream It is mandatory to procure user consent prior to running these cookies on your website. An example of such a procedure is the technical component of ambulatory electroencephalography (EEG), 95950 Monitoring for identification and lateralization of cerebral seizure focus, electroencephalographic (eg, 8 channel EEG) recording and interpretation, each 24 hours. Medicaid Fraud Control Unit receives 75 percent of its funding from the U.S. Department of Health and Human Services under a grant award totaling $9,781,180 for Federal fiscal year (FY) 2023. 0000015844 00000 n Here are some things to consider: Wondering how other allergy practices handle this? (You may have noticed if you have a referring provider, the qualifier is DN; ordering provider is DK). <> The single most comprehensive resource on billing for PA services is "The Essential Guide to PA Reimbursement," available through the AAPA Store. Billing providers will indicate whether they cover billing under these arrangements in your contract. Providers are encouraged to submit prior authorizations electronically for greater efficiency and turnaround time. 271 0 obj <>/Filter/FlateDecode/ID[<5CF22BB75017D94091BADFB78E07C3F2>]/Index[250 33]/Info 249 0 R/Length 105/Prev 245282/Root 251 0 R/Size 283/Type/XRef/W[1 3 1]>>stream Here are some things you need to consider to determine if you might be eligible to do this type of billing. <>/Rotate 0/Type/Page>> Services not meeting applicable guidelines are considered not reasonable and necessary, and are ineligible for Medicare payment; however, the rules differ depending on the type of service(s) provided. Individualized treatment plan Physician signed prior to or on start date of treatment sessions; then physician reviewed and signed every 30 days. Billing Insurance Claims Under another Provider's License, or Billing 'Incident To' Denise Hoyt, M.MFT, LMFT, LD When a provider who is not yet credentialed under a particular insurance company joins a group practice, there is often a desire for the group to be able to bill insurance for this non-credentialed provider's work. 1 impacts on providers related to a contingency fee-based system 2 significantly above the federal standard; 3 (ii) the methods and effectiveness of the state 4 department's current approach to addressing provider concerns 5 regarding the medicaid recovery audit contractor program; 6 (iii) the design, effectiveness, and methods used by other 7 states in meeting the federal standard, including: <>/Outlines 21 0 R/Pages 22 0 R/Type/Catalog>> In one practice with 11 APPs, nine of them bill incident to and two of them work independently and bill under their own NPIs. The upside is APPs have greater flexibility, including seeing new patients and existing patients with new problems. *P*>+5 <> 0000001495 00000 n Personal supervision: A physician must be in attendance in the room during the procedures performance. For services requiring direct or general supervision, the provider performing the service should document the physicians direction or presence in the office, as required by the level of supervision, and the physician should confirm with a signature. So how can you decide whether incident to billing makes sense for your practice? Registered marks of the Blue Cross and Blue Shield Association. This has nothing to do with the fact that most NPPs need a supervising physician; in that respect, the supervising physician has delineated a scope of practice for the NPP and is available for . The National Physician Fee Schedule Relative Value File assigns a physician supervision level for all CPT and HCPCS Level II codes. I have tried looking this up and only come up with "incident-to" which is not what we are looking to do. Get an NPI in the National Plan & Provider Enumeration System (NPPES) 2. Eligible Supervising Providers: A psychiatrist, psychologist, social worker, family or other therapist duly licensed and qualified in the state in which MH/SUD Services are provided, who practices as an employee of a group and has been credentialed or formally rostered and approved by United Behavioral Health (UBH), in writing, as a MHSA Group Context matters in this situation. x]An0OxfHQ pnhP,QYoGG>?|{[wq\_-6yLu;u:6~N~:?_{Dgw>qjH}ZzjUZHY2{5"5G5"E>X#bR#sF5"jDf*O*/RaUz{VV79AaUz/CaUzGU\Jor&92JPf.VPkfw}[+ How do APPs work in your practice? Most private or commercial plans do not. b&10120*mg` zw The qualifier for Supervising physician is DQ. <>stream }FSZ"QA Hb8=H&#h)iC Select the most recent (last-posted) file for download. These cookies will be stored in your browser only with your consent. The Supervisors name will populate on the Claim with the . <>stream According to Michael Rupp, MD, FACAAI, member of the Practice Management Committee, We bill incident to whenever possible, but we make sure it meets incident to criteria. A billing provider cannot hire and supervise a professional whose scope of practice is outside the providers own scope of practice as authorize under State law. The answer is maybe. %%EOF So, if an APP is the only provider seeing patients on a Saturday or at a remote location, she cant bill incident to.. A third practice bills both ways, depending on the circumstances. 34 0 obj In other words, for therapeutic services in a hospital outpatient setting: In this context, direct supervision may be defined: In the hospital or on-campus PBD includes the main building(s) of a hospital or critical access hospital (CAH): For off-campus PBDs of hospitals or CAHs, the physician or NPP must be present in the off-campus PBD, and immediately available to furnish assistance and direction throughout the procedures performance. Retaining great employees and keeping them motivated is one of the most important tasks for a successful allergy practice, 2023 American College of Allergy, Asthma & Immunology | Policies | Terms of Use | Built by Social Driver. CMS designates several supervision categories specific to physical therapy services. Medicare still allows mid-level practitioner services to be billed under the physicians NPI and paid at the higher physician rate but only if the incident to requirements are met. %$o5 ZCw6:5?OYRp}Zc#"*[ 63q^vA":z|6a3Ah^ol`%IJr{ ,TG^C|1Z1|c3wpA6*o_]!4=Zu,cY. The services provided must be under the scope of practice of the rendering provider AND the supervision provider. You are using an out of date browser. for which the hospital or CAH bills the services furnished under the hospitals or CAHs CMS Certification Number. An independent licensee of the Blue Cross and Blue Shield Association. You must log in or register to reply here. 0000003043 00000 n This website uses cookies to improve your experience while you navigate through the website. The mid-level practitioner can only see patients for existing problems, not new problems. 379 0 obj <> endobj <>stream 0000011030 00000 n endobj J ouV%,X3Uk,V^X7j1F}6yjM({fP7yF^cy+%X#Wj(N+ For services provided in the hospital or on-campus PBD of the hospital, the physician or NPP must be present on the same campus and immediately available to furnish assistance and direction throughout the procedures performance. Were here to help. Sign up for a hands-on workshop, and youll leave ready to implement what youve learned into your practice. One side note: the allergist who initiates the plan of care does not need to be the same allergist who supervises the NP it can be another allergist in the group. 0000020689 00000 n For diagnostic services in an outpatient setting (hospital outpatient or physician office), only a doctor of medicine or osteopathy legally authorized to practice medicine in his or her state of practice, as defined by 1861(r) of the Social Security Act, may act as a supervisory physician. <> 0000003618 00000 n Necessary cookies are absolutely essential for the website to function properly. TheDIY Credentialing 101 e-course is LIVE! For example: Policy: The manual update clarifies where physician's Provider Information Numbers and names should be reported when both an ordering provider and a supervising provider are involved in a service. Coverage Table: Mental Health Services . Yes . 3. Under Medicare, this results in a 15% reduction in reimbursement from the physician fee schedule. JavaScript is disabled. 0000001848 00000 n You also have the option to opt-out of these cookies. For instance, the concept of physician supervision would not apply to surgical procedures such as 29806 Arthroscopy, shoulder, surgical; capsulorrhaphy. hbbd```b``63@$S3 fW Dj`XD0LH. endobj Not surprisingly, Medicare sets the rules for how to bill for advanced practice providers (APPs), which include NPs and PAs. A physician always must provide the professional component (reading/interpreting of results) for diagnostic services. The 2010 Hospital Outpatient Prospective Payment System (OPPS) Final Rule verifies, Physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse midwives who do not meet the definition of physician may not function as supervisory physicians for the purposes of diagnostic tests (Federal Register, Nov. 20, 2009). . endstream k) D/>_:M8_uk~ou For Outpatient Diagnostic Services, a Physician Must Supervise Allergy practices are increasingly hiring nurse practitioners (NPs) and physician assistants (PAs) to grow practice revenue and improve allergist satisfaction and patient care. 0 `|Sn4nuU}'+Ap )_e-2 The patient record should document essential requirements for incident to service. Privacy Policy | Terms & Conditions | Contact Us. supervision (office based), e.g. 0120Y@, These categories assign the required level of supervision based on the providers level of training: %PDF-1.6 % To get Medicare payment: 1. I'm not understanding your response, as it appears different than your original question. 7a Supervision standards for level 77 apply; in addition, the PT with ABPTS certification may supervise another PT but only the PT with ABPTS certification may bill. endobj endobj He has been covering medical coding and billing, healthcare policy, and the business of medicine since 1999. 40 0 obj The downside is a reduction in reimbursement. }>GsX8vs}t[o We are looking for thought leaders to contribute content to AAPCs Knowledge Center. NPPs who provide an allowable "Assistant-at-Surgery" service will be reimbursed at 85% of 16% of the MPFS fee for the surgical procedure [example: CPT xxxxx = $1,000 at the MPFS fee. The two principal incident to requirements when billing for services of NPs or PAs are: While NPs and PAs are permitted to see Medicare beneficiaries for new problems without direct supervision (if permitted under state law) those services must be billed under the NPs or PAs own NPI number at the 85% reimbursement rate. 0000079030 00000 n Most states are either silent on student-provided services or exclude those services from reimbursement. Lastly, this billing practice is most common when M.D.s or D.O.s are the supervising provider. The remaining 25 percent, totaling . J. Kelly Davis, BS, CMPE, member of the Practice Management Committee, notes, More commercial payors are requiring APPs to be credentialed separately and bill under their own NPI.. 2. <> It is critical to determine if your site and credentials allow you to provide incident-to billing services. HCPCS codes submitted on the CMS1450 are matched to . Under Medicare, this results in a 15% reduction in reimbursement from the physician fee schedule. Note: Medicare physician supervision requirements do not apply to hospital inpatient services. 0000069552 00000 n <>stream If you are a solo practitioner you must be on site to supervise. Make sure youre billing for their services properly and maximizing your reimbursement. xref 0000009560 00000 n Our NPs practice without supervision. 27 0 obj i. Hospital-based billing typically occurs using a CMS-1450 form, also known as a Universal Billing (UB)-04. These apply specifically to outpatient diagnostic services. For a facility charge to be billed, it would typically be billed on this form under the supervising provider's NPI.4 1. This issue we were experiencing last week with the online prior authorization tool has been resolved. 0000037339 00000 n <> John Verhovshek, MA, CPC, is a contributing editor at AAPC. Include direct supervision attestation statements for "incident to" billing arrangements Permissible "incident to" billing requires direct supervision from the supervising physician. endobj Is that fraud or is it okay? endobj 42 0 obj In the physician office, the supervising physician must be present in the office suite and immediately available to furnish assistance and direction throughout the procedures performance. No Yes, but the provider must be in an OPC and: LLMSWs must work under an LMSW.
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