To be in compliance with the HCFA guidelines for the supervising MD, as I
understand the language, is that you have to be present during the "key"
portion of the procedure to bill for it. So, I would have to say that your
compliance officer is correct.

The definition of the "key part" is obviously subject to interpretation. For
an LP it would seem logical that it is during needle insertion. For suturing
it need not be during the procedure but perhaps on completion, to ensure an
adequate cosmetic result. Moreover, if you are involved in any part of the
pre-procedure teaching, I document that as well.

Yes, I realize that all this documentation becomes onerous. We are therefore
moving towards checklist charting with standard documentation for the most
common procedures like spinal taps.

Hope that helps

Jay Pershad, MD

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