Supervising Physicians

Supervision means the imaging is done under the physician’s overall control and direction and the licensed supervising physician is directly overseeing and ensuring the quality of medical care.

An IDTF must have one or more supervising physicians who are responsible for the direct and ongoing oversight of the quality of the testing performed.

The supervising physician must evidence proficiency in the performance and interpretation of each type of diagnostic procedure performed by the IDTF.

In the case of a procedure requiring the direct or personal supervision of a physician as set forth in Section 410.32(b)(3)(ii) or (b)(3)(iii), the IDTF’s supervising physician must personally furnish this level of supervision whether the procedure is performed in the IDTF or in the case of mobile services, at the remote location.

The IDTF must maintain documentation of sufficient physician resources during all hours of operations to assure that the required physician supervision is furnished. In the case of procedures requiring direct supervision, the supervising physician may oversee concurrent procedures.

With the different levels of supervision, the physician may have to be in the facility and immediately available, but is not necessarily required to be in the room where some services require the supervising physician to be in the room.

Levels	Definition of Supervision
01 – General supervision	The procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. The training of the nonphysician personal that actually performs the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibilities of the physician.
02 – Direct supervision	In the office setting means the physician must be present in the office suite and immediately available to furnish the assistance and direction throughout the performance of the procedure. The physician does not need to be present in the room when the procedure is performed.
03 – Personal supervision	A physician must be in attendance in the room during the performance of the procedure.

The supervision level required for diagnostic services is assigned by CMS. A list of diagnostic procedures and the supervision level required for each service is available in the CMS Medicare Physician Fee Schedule Database.

For example:

Supervising physician(s) shall submit copies of all documentation verifying proficiency (resume) and state licenses or certification.
Each supervising physician must be limited to providing supervision to no more than three IDTF sites.
The supervising physician must also attest to supervising responsibilities for the enrolling IDTF.

Under 42 CFR, Section 410.33(b)(1), an IDTF must have one or more supervising physicians who are responsible for the following:

The direct and ongoing oversight of the quality of the testing performed
The proper operation and calibration of equipment used to perform tests
The qualifications of nonphysician IDTF personnel who use the equipment

All supervising physician functions must be properly met at each location, regardless of the number of physicians involved. This is particularly applicable to mobile IDTF units that are allowed to use different supervising physicians at different locations. They may have a different physician supervise the test at each location. The physicians used need only meet the proficiency standards for the tests they are supervising.

Note: Each supervising physician must be limited to providing supervision at no more than three IDTF sites. This applies to both fixed sites and mobile units where three concurrent operations are capable of performing tests.

Supervising physicians must meet the following criteria:

Be licensed to practice in the state(s) where the diagnostic tests they supervise will be performed
Be enrolled in Medicare; however, the physician(s) need not necessarily be Medicare enrolled in the state where the IDTF is enrolled
Meet the proficiency tests for any tests they supervise
Is not currently excluded or barred
Provide general supervision for no more than three IDTF sites

Supervising Physicians

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