Legislative Update

The Radiology Physician Extender community just passed a huge milestone in our quest to become a recognized midlevel radiology provider. On July 12th the Centers for Medicare and Medicaid Services (CMS) released the Medicare Physician Fee Schedule (MPFS) 2019 proposed rules. CMS is proposing to reduce supervision levels on diagnostic tests performed by the "radiologist assistant (RA)" which includes the Registered Radiologist Assistant (RRA) and Radiology Practitioner Assistant (RPA), from "personal" to "direct" supervision.

The proposed rule was officially published in the Federal Register on July 27, 2018. The Final Rule will be published in November and the SRPE needs your help for the RA rule to be included.

The SRPE encourages everyone to write comments in SUPPORT of this proposed rule. Please use wording similar to the following:

“I write in strong support of the Centers for Medicare & Medicaid Services (CMS) proposal to revise its regulation at 42 CFR §410.32 to add a new paragraph (b)(4) to state that diagnostic tests performed by a Radiologist Assistant (RA) require only a direct level of physician supervision, when permitted by state law and state scope of practice regulations.

In addition to the proposed change, I encourage CMS to: 1) clarify in its final regulation that all services with the RA’s scope of practice, including procedures, may be performed under direct supervision; and 2) ensure that the proposed policy be effective January 1, 2019 by providing any necessary administrative guidance (e.g. issuance of a billing modifier).”

Here is link for comment submissions. https://www.regulations.gov/comment?D=CMS-2018-0076-0621

Please submit your comments before the comment close date of September 10, 2018!