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. This makes permanent a temporary provision in place since May 2021.
“This is a significant change from CMS that better aligns Medicare coverage policy for diagnostic tests with the state scope of practice of nurse practitioners,” says Nancy McMurrey, vice president of communications, American Association of Nurse Practitioners. “This policy was initially implemented for the duration of the COVID-19 Public Health Emergency (PHE), and it improved patient access to testing … at a time when this was much needed in their communities. Making this policy permanent will continue this expanded access to diagnostic testing for Medicare patients.”
Michael Powe, vice president of reimbursement and professional advocacy for the American Academy of Physician Assistants, called CMS’ decision “an important step in removing a regulatory barrier that previously hindered the ability of PAs and NPs to practice medicine efficiently. With the looming shortage of physicians and the need to increase patient access to care, it is imperative that PAs and other health professionals practice to the top of their education and competency.”
Lab expert Jim Poggi, Tested Insights, LLC, says 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 differential diagnosis of respiratory infection more comprehensive and timely, he says.
Expand accessibility of testing
Prior to the waiver (and ultimately the final rule), if Medicare required clinician orders for coverage of a diagnostic test, nurse practitioners could complete those orders and Medicare would cover the test, says McMurrey. NPs were also authorized to perform diagnostic tests and have those tests covered by Medicare. “However, prior to this rule change, if another member of the clinical staff – for example, a registered nurse – performed the test, that clinical staff member would have to be under the general supervision of a physician in order for Medicare to cover the test. Now, with the rule change, an NP is authorized to supervise the clinical staff member and have the test covered by Medicare. This is a new Medicare policy, but this is consistent with state policies that were already in effect.
“It 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.”
Says Powe, “Previously, for certain diagnostic tests, there was a requirement for a physician to be physically onsite to meet Medicare’s 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.”
Poggi believes the final rule should serve as a reminder to Repertoire readers that they should routinely inform all their clinicians of the importance of lab testing and remind them of the product portfolio available to them through their companies. “Within the complex decision-making process of larger group practices, it is always wise to consult the office manager or lab director before approaching other members of the clinical staff to assure they know and understand your approach.”