900.2(o)(1): Direct Supervision means that: During joint interpretation of mammograms, the supervising interpreting physician reviews, discusses, and confirms the diagnosis of the physician being supervised and signs the resulting report before it is entered into the patient’s records.
The goal of direct supervision is to provide reasonable assurance that any mistakes made by the physician being supervised are corrected before harm is done to the patients.
The supervising interpreting physician does not have to be present when the physician being supervised makes his or her initial interpretation. However, the supervising physician must review and, if necessary, correct the final interpretation before it is given to the patient.
When the physician being supervised reads previously interpreted mammographic examinations, these interpretations must still be reviewed, discussed and confirmed or corrected by a supervising interpreting physician. This must be done even if the supervised physician’s interpretation agrees with the previous interpretation and/or the interpretation of the supervising interpreting physician. If mammographic examinations are being read retrospectively under direct supervision, the usual requirement that the multireading be done before the patient receives her results is waived.
When mammographic examinations are read prospectively under direct supervision, at a minimum, the qualified supervising interpreting physician must sign the report.
Physicians working to meet one or more of the initial qualifications are still considered physicians-in-training and must continue to read under direct supervision until all initial qualifications have been met.
- Under what conditions may students, trainees, interns, or residents work at facilities (interpreting mammograms) to obtain knowledge and experience prior to meeting the appropriate initial qualifications?
- During annual MQSA inspections, mammography personnel are sometimes found to not meet one or more of the personnel qualifications. May this individual (interpreting physician) continue to lawfully provide mammography services to the facility?
- If personnel, such as interpreting physicians do not start working directly in mammography after meeting all their initial requirements, but decide to start working at a mammography facility later, what must they do to make sure they are in compliance with MQSA? What should facilities do before allowing new personnel, including locum tenens or those personnel who have left the facility but returned later, to provide mammography services?
- What does it mean for a physician to be under the direct supervision of a qualified interpreting physician? Does the supervising physician have to sit next to the physician being supervised when he or she reads and interprets the film? Whose name goes on the report, the supervising physician or the physician being supervised?
- Do general supervisors of interpreting physicians have to meet any requirements under MQSA?
- Physician A is under the direct supervision of physician B who works at another facility. Physician B provides a letter documenting the number of examinations for which he/she provided direct supervision. Must physician B also include documentation showing that he/she is a qualified interpreting physician?
- Can direct supervision of an interpreting physician be provided exclusively through the use of telemammography?
- If the person providing direct supervision is found to be unqualified, how does that affect the status of the person being supervised?
Personnel who have met the initial requirements and are undergoing requalification after failing to meet any of the continuing requirements should not be considered trainees. Therefore, their names and associated information should be collected and recorded in the inspection record. The inspector should indicate the person’s requalifying status in the remarks section. When queried regarding requalifying personnel’s continuing education, the inspector should enter an "X."
Documentation: It will generally be sufficient if the interpreting physician’s file contains a letter, table, or printout from each facility at which he or she interprets mammography examinations, signed by the person performing the direct supervision or a responsible facility official. The document should state who provided the direct supervision and that the interpreting physician interpreted or multi-read a given number of examinations at that facility in a given time period. It is assumed that these numbers are based upon more extensive records, such as facility logs, that can be reviewed if there are any questions. The facility logs themselves can then be used as documentation. Provision of summary letters, tables, or printouts will speed up the inspection and rarely will the more detailed records be requested.