Q&A: CMS supervision requirements for outpatient wound care

Q: What level of supervision is required for wound care services performed in an off-campus, provider-based outpatient department?

A: Effective January 1, 2020, CMS requires, as the minimal level of supervision, general supervision for services performed on hospital outpatients. General supervision means that the services are furnished under the physician's overall direction and control, but that the physician's presence is not required.

Previously, off-campus, provider-based departments billed wound care under direct supervision, which required a physician to be "immediately available" when these services are being provided to Medicare beneficiaries.

Now the physician needs to be generally available (e.g., via phone or email) but not directly on campus or in the building where the procedure is taking place. This change allows nurses to perform wound care services within their scope of practice without direct oversight.

CMS has repeatedly stated that hospitals may choose to adopt higher levels of supervision for more complex services at their discretion.

Editor’s note: This question was answered by Gloria Miller, CPC, CPMA, CPPM, vice president of Revenue Cycle Management at Comprehensive Healthcare Solutions Inc. in Tacoma, Washington, during the HCPro webinar “Revitalize ICD-10-CM and CPT Coding for Wound Care.”