Delegated Procedures

Procedures which are generally and traditionally accepted as those which may be carried out by a nurse, nurse practitioner or a medical assistant in the employ of a medical practitioner may, when so performed, only be billed to MSP by the medical practitioner when the performance of the procedure is under the “direct supervision” of the medical practitioner or a designated alternate medical practitioner with equivalent qualifications. Direct supervision requires that during the procedure, the medical practitioner be physically present in the office or clinic at which the service is rendered. While this does not preclude the medical practitioner from being otherwise occupied, s/he must be in personal attendance to ensure that procedures are being performed competently and s/he must at all times be available immediately to improve, modify or otherwise intervene in a procedure as required in the best interest of the patient. Billing for these procedures also implies that the medical practitioner is taking full responsibility for their medical necessity and for their quality. Any exceptions to this rule are subject to the written approval of MSP.

“Procedures” in this context do not include such “visit” type services as examinations/ assessments, consultations, psycho-therapy, counselling, telehealth services, etc., which may not be delegated. 

The foregoing limitations do not apply to approved procedures rendered in approved “diagnostic facilities”, as defined under the Medicare Protection Act and Regulations and which are subject to accreditation under the Diagnostic Accreditation Program. 

Diagnostic Facility Services 

Diagnostic Facility Services are defined under the Medicare Protection Act as follows: “Medically required services performed in accordance with protocols agreed to by the Commission, or on order of the referring practitioner, who is a member of a prescribed category of practitioner, in an approved diagnostic facility by, or under the supervision of, a medical practitioner who has been enrolled, unless the services are determined by the Commission not to be benefits.” 

The Medical Services Commission designates, from time to time, certain diagnostic procedures as “diagnostic facility” services under the MSC Payment Schedule. Currently, the following services are considered “diagnostic facility” services for purposes of the MSC Payment Schedule: 

a. the services, studies, or procedures of laboratory medicine, diagnostic radiology, diagnostic ultrasound, nuclear medicine scanning, pulmonary function, computerized axial tomography technical fee (CT, CAT), magnetic resonance imaging (MRI), positron emission tomography (PET), and electro diagnosis (including electrocardiography, electroencephalography, and polysomnography), or 

b. the taking or collecting of specimens in an approved diagnostic facility for the purpose of diagnosis, treatment or prevention of a human ailment. Such services are not payable by MSP for services rendered to hospital in-patients, “day surgery” patients, or emergency department patients. 

The venepuncture and dispatch listings in the Payment Schedule (00012 and 90000) apply only to those situations where this sole service is provided by a facility or person unassociated with any other bloodwork services provided to that patient. Fee items 00012 and 90000 cannot be billed or paid to a medical practitioner or a laboratory if any other bloodwork assays are performed or if the specimen is sent to an associated facility.