Following the end of the Public Health Emergency, the American College of Radiology (ACR) updated its supervising physician requirements for contrast administration. This follows a marked change that took place in the early 2020s, which allowed non-physician providers (NPPs) in radiology to directly contrast administration. In late 2024, the ACR once again updated this policy, reversing certain criteria permitted during the state of emergency.
Contrast Injection and Supervision Requirements
The two most important players in contrast administration are the injector and their supervisor. According to ACR guidelines, these can be two different people, and the base qualifications are different:
- Injector: The provider directly administering the contrast injection should be appropriately credentialed and allowed by state law and site policy. That includes technologists, registered radiology assistants (RRAs), registered nurses (RNs), nurse practitioners (NPs) and physician assistants (PAs)
- Supervisor: While qualified injectors were allowed to supervise injections during the Public Health Emergency, this guideline has reverted to its original qualifications. That direct supervision can be met by an on-site radiologists, other physician or a qualified licensed practitioner, as allowed by state law and site policy.
You can learn more about the specific requirements of each provider on the ACR's website.
Radiology Billing for Non-Physician Requirements
While the ACR published clinical guidance and accreditation expectations, federal and state rules, plus payer policy, drive what is required for billing and supervision. Furthermore, when it comes to the billing aspect of these services, it is important to note that Medicare in particular has its own standards for supervision.
For Medicare, services billed under an NP/PA's own natural provider identifier (NPI) are generally paid at 85% of the physician's rate. If all "incident to" rules are met, payment can be at 100%. Still, given the costs of paying NPPs over physicians, many practice use NPPs where allowed to support access and workflow. Billing must still match scope, supervision rules and payer policy.
Stay up to Date With Supervising Physician Requirements
As the healthcare industry continues to recover following the Public Health Emergency of the COVID-19 pandemic, NPPs are more important than ever in facilitating quality care and operating with legal limitations as dictated by local and state regulations. As such, billing, coding and RCM teams must be prepared to mange changing standards and how they vary from logging services from board-authorized providers. Stay updated on the latest ACR policies and other essential changes when you subscribe to our blog.
Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.
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