Allied Professionals Community of Practice

Hi Terri,

All device in-person checks are considered by CMS to be Diagnostic Testing and thus fall under the "Direct Supervision" rule.  Direct supervision means there must be a physician readily available ("on campus" ) to provide assistance and direction.  There is no requirement that the  physician be in the room during the procedure.  CMA uses the term "Personal Supervision" when the MD is required to be in the room during a procedure, and this is not the requirement for device checks.

In addition, CMS amended the definition of "Direct Supervision" in Jan 2021   to permit non-MD practitioners, such as qualified APPs, to supervise diagnostic tests in states where it is allowed by state law and scope of practice.  Here is a link to that document:  www.cms.gov/files/document/12120-pfs-final-rule.pdf

It is in section 410.32, page 1737

Hope this helps,

Sallie Gustafson, RN, CCDS, Sr Manager, Emory Cardiac Device Clinics

We are considering sending an RN to do device checks in Community Outreach clinics without a physician present. Looking through the final rule, it appears the telehealth/remote ability to "direct supervise" is only applicable during the COVID-19 pandemic public health emergency.  After that time, would an APP or physician need to be present?

Thanks for your response,

Eileen

Eileen Yeisley, DNP, ARNP, NP-C

Adult Cardiac Electrophysiology

The University of Iowa, Hospitals and Clinics

200 Hawkins Drive

C466 General Hospital

Iowa City, Iowa 52242

Phone: (319) 353-8883

Pager: 9545