Direct Supervision of Hospital Outpatient Services

As of Jan. 1, 2014, CMS ended the direct supervision enforcement moratorium for critical access hospitals (CAHs) and small rural hospitals. This means that all hospitals must comply with CMS’s direct supervision requirements. The August 25-26, 2014 meeting will be the last opportunity this year to have individual outpatient therapeutic services re-designated as “general supervision” services. Please see the HOP Action Alert  from June 18, for additional information.

The number and variety of services that the HOP Panel considers will directly depend upon how many hospitals request to testify before the panel and the services they present for evaluation. CMS has reduced the level of supervision for 56 outpatient therapeutic services based on recommendations made by hospitals that have presented at HOP Panel meetings since 2012. The list, which can be found on the CMS website, now includes the following seven services, discussed by the HOP Panel at its March meeting that CMS just approved for general supervision effective July 1, 2014:

  • CPT 36430, Transfusion, blood or blood components
  • CPT 36593, Declotting by thrombolytic agent of implanted vascular access device or catheter
  • CPT 36600 Arterial puncture, withdrawal of blood for diagnosis
  • CPT 94667, Manipulation chest wall, such as cupping, percussing, and vibration to facilitate lung function; initial demonstration and/or evaluation
  • CPT 94668, Manipulation chest wall, such as cupping, percussing, and vibration to facilitate lung function; subsequent
  • CPT 96370, Subcutaneous infusion for therapy or prophylaxis (specify substance or drug); each additional hour
  • G0176, Activity therapy, such as music, dance, art or play therapies not for recreation, related to the care and treatment of patient’s disabling mental health problems, per session (45 minutes or more)

Hospitals may request a change in supervision level for any outpatient therapeutic service that has not previously been considered by the HOP Panel. A list of all of the services previously evaluated by the HOP Panel can be found on the CMS website.

In a recent statement, CMS requested that presentations be made at the upcoming August HOP Panel meeting that focus on the clinical case to keep or amend supervision status of the following CPT codes for the administration of chemotherapy, complex drugs or biologic agents: CPT 96401, 96402, 96409, 96411, 96413, 96415, 96416 and 96417.

Specifically, CMS is interested in presentations about whether these codes should be designated direct supervision only for the initial administration (first administration in a series of administrations of the same drug) followed by general supervision for all subsequent administrations of the same drug. While we view this development as a positive step, CMS needs to hear from many hospitals willing to make presentations on this approach.

Submit a presentation recommending general supervision for specific outpatient therapeutic services and make a request to testify during the August meeting. As noted above, we urge hospitals to consider testifying, in particular, about CMS’s suggested approach for the supervision of chemotherapy administration services. Examples of hospital presentations that CMS has accepted for previous HOP Panel meetings are available on the AHA website.

  • Refer to the notice in the May 9 Federal Register for detailed instructions on CMS’s requirements.The deadline for submitting an email copy of a presentation and a completed Form CMS – 20017 is July 25. You must submit both documents.
  • CMS will review all requests and select presenters to testify at the August meeting.
  • Presenters and other individuals interested in attending the August meeting in person must register online between June 30 and Aug. 1.
  • Review the attached AHA Factsheet for more information.

Members interested in testifying can contact Roslyne Schulman, AHA director of policy, at or (202) 626-2273 for technical assistance on presentations and requests.



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