Physician fee schedule: With scope of practice changes, CMS loosens authority for many providers

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains how CMS used the 2021 Medicare physician fee schedule to revise scope of practice and supervision policies for multiple provider groups. It focuses on changes affecting non-physician practitioners, pharmacists, therapy assistants, and teaching physician arrangements, along with permanent and temporary flexibilities tied to the public health emergency. The piece is relevant to coding, compliance, and revenue cycle professionals who need to understand which services and supervision arrangements are being expanded, limited, or made permanent.

Why This Topic Matters

These Medicare policy changes affect how services are supervised, documented, and billed across multiple provider types and care settings. Understanding the scope of practice updates helps organizations assess compliance risk and prepare for changes to teaching physician and office/outpatient payment policies.

Article Sections

  1. CMS scope of practice changes under the 2021 physician fee schedule

    An overview of CMS policy changes affecting non-physician practitioners and other qualified health professionals. The section frames the final rule in the context of scope of practice and broader Medicare policy updates.

  2. Allowances extended beyond the public health emergency

    A summary of several flexibilities CMS approved for different provider groups and service categories. The section discusses supervision, incident-to services, maintenance therapy, and medical record documentation review.

  3. Teaching physician flexibilities and permanent changes

    Coverage of temporary and permanent adjustments affecting teaching physicians, residents, and supervision arrangements. The section also addresses documentation expectations and setting-based differences.

  4. Teaching physician supervision requirements and selected procedures

    Discussion of the mode of supervision CMS expects for teaching physicians and how certain procedure types remain subject to in-person requirements. The section references selected procedure code examples.

  5. Primary care exception changes at the end of the public health emergency

    An outline of how the expanded primary care exception will be reduced after the public health emergency ends. The section identifies the affected office and outpatient E/M code families.

What You Will Learn

  • How CMS is updating scope of practice policy in the 2021 Medicare physician fee schedule
  • Which types of providers are affected by the scope and supervision changes
  • How teaching physician and resident supervision flexibilities are being handled during and after the public health emergency
  • Which policy areas are becoming permanent and which remain temporary
  • How the article frames documentation and setting considerations tied to these Medicare changes

Who Should Read This

  • Medical coders
  • Compliance staff
  • Revenue cycle teams
  • Practice managers
  • Physician offices
  • Hospital billing departments
  • Medical auditors

Codes Discussed


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