Radiologist Required to Supervise ASC Radiological Services

The following article appeared in the May 2010 issue of Connection, the bi-monthly e-newsletter from the AAAHC.

Q. My ASC is Medicare certified and we use a C-Arm; does CMS really require that a radiologist supervise radiological services?

Michon Villanueva, Assistant Director, Accreditation Services, AAAHC: Yes, CMS expects ASCs that provide any radiological services to meet the condition 416.49 Laboratory and Radiologic Services and more specifically, 416.49(b) Standard: Radiologic Services, which requires:

(2) Radiologic services must meet the hospital conditions of participation (CoPs) for radiologic services specified in 482.26 of the CoPs.

One of the requirements, 482.26(c) Standard: Personnel, requires:

A qualified full-time, part-time or consulting radiologist must supervise the ionizing radiology services and must interpret only those radiologic tests that are determined by the medical staff to require a radiologist's specialized knowledge. For purposes of this
section, a radiologist is a doctor of medicine or osteopathy who is qualified by education and experience in radiology.

CMS interpretive guidelines reinforce that supervision of radiology services may only be performed by a radiologist who is a member of the medical staff. The radiologist that is privileged to supervise radiology services accepts the responsibility for the provision of
such services. As a reminder, the radiologist can be full-time or part-time and does not necessarily have to be present all the time. The governing body must determine the requirements of the supervising radiologist. ASCs can seek a radiologist to add to the medical staff or, as noted specifically in the requirement, the ASC may choose to
contract with a consulting radiologist.

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