For the public health emergency (PHE), CMS altered the definition of “direct supervision” to permit the presence
and “immediate availability” of the supervising practitioner through “real-time audio and visual interactive
telecommunications.” CMS will continue this policy through December 31, 2024 (it will also be extended to FQHCs
and RHCs). (Reference Page, p. 167).
Additionally, for the supervision of teaching residents, the teaching physician may continue to have a virtual presence
in all teaching settings but only in clinical instances when the service is furnished virtually. Otherwise, the teaching
physician would need a physical presence unless the service is performed at a residency training site outside
of a Metropolitan Statistical Area (MSA). This exception for virtual presence in teaching settings during services
furnished virtually will continue through December 31, 2024. Both supervision temporary waivers exclude this from happening via audio-only. (Reference Page, p. 171).
CMS will establish an RTM general supervision policy for physical and occupational therapy practitioners in private practice who are supervising physical therapist (PT) and occupational therapist (OT) assistants. The direct supervision requirement for unenrolled PTs and OTs will continue. (Page Reference, p. 495)
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