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It’s finally happened. It’s no secret that many Hospital Based Outpatient Departments (HOPDs) have played fast and loose with the requirement for direct physician supervision of nearly all wound management services. At any rate, the requirement for direct physician supervision of services in the HOPD is gone, and that includes hyperbaric oxygen therapy. Here’s what they said:

“After reviewing all of the public comments, we are finalizing our proposal for CY 2020 and subsequent years to change the generally applicable minimum required level of supervision for hospital outpatient therapeutic services from direct supervision to general supervision for services furnished by all hospitals and CAHs without modification… safeguards include allowing providers and physicians the discretion to require a higher level of supervision to ensure a therapeutic outpatient procedure is performed without risking a beneficiary’s safety or their quality of the care…”

I am not sure what this means, since it will be hard to justify paying a doctor to supervise a treatment if they don’t have to be there. Hospitals can decide that they want direct supervision of HBOT, but that doesn’t mean it will be reimbursed. Stay tuned.


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