May 14, 2020
In an effort to phase our office “re-opening” to patients during the COVID pandemic, allergy serum that needs to be mixed in preparation must be done and at times there may not be on-site direct supervision by a physician or QHP. Medicare states direct supervision is required. Can we use virtual supervision for this?
Since CMS changed the definition of direct supervision temporarily to include real time audio and video supervision, then yes – this would include direct supervision to oversee serum mixing, as long as the physician feels that virtual supervision would clinically acceptable.
Of course, this means the physician will need to be live on a device during the entire process of mixing the allergy serum, and not just on the phone or available by phone. Thank you.
*This response is based on the best information available as of 05/14/20.