Hospital Outpatient Services: New CMS Supervision Requirements

Complying With the New Rules to Protect Medicare Reimbursement

Recording of a 90-minute CLE webinar with Q&A

Conducted on Thursday, April 22, 2010

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will prepare healthcare counsel to guide hospitals through the implementation of the new CMS supervision requirements for outpatient services. The seminar will identify open issues the new requirements create and explain common implementation challenges.


The Centers for Medicare and Medicaid Services (CMS) issued new rules effective Jan. 1, 2010 requiring on-campus hospital outpatient services to be directly supervised by an appropriately qualified physician or, in certain circumstances, by certain nonphysician practitioners (NPPs).

Complying with the rules will be challenging and costly. Hospitals must identify appropriately qualified physicians and NPPs, hire additional supervisors, and perhaps eliminate services. Consequences for noncompliance include recoupment of overpayments and possible False Claims Act violations.

Listen as our panel of healthcare attorneys explains the practical implications of the new CMS supervision requirements for outpatient services, identifies open issues the new rules create, and discusses how hospitals should respond to common supervision challenges.



  1. Overview of new rule
    1. Nonphysician practitioner (NPPs) supervision
    2. Qualifications of physician or NPP
    3. Therapeutic services
    4. Diagnostic services
    5. On-campus services
    6. Off-campus services
    7. Under arrangements
  2. Compliance challenges for hospitals
    1. Identifying qualified physicians and NPPs
    2. Elimination of services?
  3. Next steps for hospitals
    1. Assess outpatient operations
    2. Evaluate resources and physician relationships to create supervision plan
    3. Review and revise supervision policies and procedures


The panel will review these and other key questions:

  • How do the new CMS requirements for physician supervision of hospital outpatient services impact hospital operations?
  • What challenges will hospitals face in implementing the new supervision requirements?
  • What steps should hospitals take immediately to ensure compliance with the new rules?


Brown, Lowell C.
Lowell C. Brown

Arent Fox

He serves as Chair of the Health Care Practice Group. He advises hospitals, health systems, long-term care facilities,...  |  Read More

Lawrence C. Conn
Lawrence C. Conn

Special Counsel
Foley & Lardner

He represents hospitals, physicians, clinical laboratories, pharmacies, and therapy and DME suppliers on a wide range...  |  Read More

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