Changed Role of Non-Physician Practitioners (NPPs) in Diagnostic Testing

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Changed Role of Non-Physician Practitioners
(NPPs) in Diagnostic Testing
Effective January 1, 2021, CMS permits
Non-Physician Practitioners (NPPs) such as Nurse
Practitioners (NPs) and Physician Assistants
(PAs) to supervise diagnostic tests (including
CIED management) only in states where it is
allowed by state law and scope of practice. In
all other states, only a physician can supervise
diagnostic tests.   Previously, CMS permitted
non-physician practitioners to order diagnostic
tests (including CIED management) but the
regulations did not address whether these
practitioners could supervise others who
furnished diagnostic tests. This policy was
initially implemented for the duration of the
COVID-19 Public Health Emergency (PHE). In May
2021, this temporary provision was made
permanent. Making this policy permanent will
continue this expanded access to diagnostic
testing for Medicare patients. Nurse
practitioners, physician assistants, clinical
nurse specialists, and certified nurse-midwives
have the green light to supervise the performance
of diagnostic tests even after the COVID-19
public health emergency has ended, per the 2021
Medicare Physician Fee Schedule.
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Changed Role of Non-Physician Practitioners
(NPPs) in Diagnostic Testing
The new schedule expands the number of
individuals who can order COVID tests beyond the
traditional boundaries allows patient-directed
testing, permitting patients to perform sample
collection at home and send the sample to a
laboratory and also permits a wider range of
acceptable testing locations, including
drive-through and pop-up testing sites. It also
applies to tests for influenza and RSV and will
make the differential diagnosis of respiratory
infection more comprehensive and
timelier. Telehealth Services While adding a
number of additional services that can be
provided via telehealth, CMS stated it does not
have the statutory authority to authorize
permanent payment for telehealth delivered in
non-rural areas or for any patients located in
their homes. COVID-19 PHE waivers currently allow
Medicare coverage for telehealth services in
urban areas and for beneficiaries in their
homes. CMS will not reimburse for audio-only
telephone E/M services after the PHE ends. The
agency proposes to create a new virtual check-in
code for longer conversations.  
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Changed Role of Non-Physician Practitioners
(NPPs) in Diagnostic Testing
Office E/M Documentation CMS also confirmed
that Evaluation and Management documentation
guidelines for office services will be based on
either medical decision-making or time. Recording
the history and exam are still necessary
components for the medical record but will not be
used to determine the visit level code submitted
for reimbursement.   Prior to the
Waiver Previously, for certain diagnostic tests,
there was a requirement for a physician to be
physically onsite to meet Medicares supervision
requirements. Under the old rules, if a physician
left the office to round at the hospital, for
example, and a patient came in for a visit and
needed a certain diagnostic test, the test might
not be able to be performed if a PA was present
in the office. The patient might be forced to
return on a different day to have the test
performed. With the new regulation authorizing
PAs to supervise diagnostic tests, that same
patient could receive the test on the same day as
their office visit, avoiding an additional visit
to the practice.
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Changed Role of Non-Physician Practitioners
(NPPs) in Diagnostic Testing
This rule will expand the accessibility for
patients, improve efficiencies for Medicare
patients, and allow practices, including those
owned by nurse practitioners, long-term-care
facilities, and other settings to utilize their
clinical staff to a fuller extent.