So what is the point in supporting it? How often are you on site? What is the harm in requesting someone on site for >50%? Why open the field up to the possibility of exploitation of a stupid rule when the people calling for it are still like "yeah, but i'm there 90%"?
@ ESE
1) What is the stringency with which errors have been looked for?
2) No one is talking about direct supervision anymore, we are talking about flexibilities.
3) Yeah, it probably did.
4) Agreed 0-50% is complete BS, clearly you need good docs on site at least a large majority of the time, but no 100% of the time.
1) Across all hospitals across all of medicine? Not great, but not zero. MedPac was at least out in the field talking to doctors and hospitals, I'll give them that.
I would highlight to everyone the most recent "error" in RadOnc (wrong site breast treatment) was done under Direct Supervision (by ASTRO leadership no less).
2) Ok but like, what are these "flexibilities"? Who is defining them? What is the mechanism of enforcement? Is CMS is going to create very niche carve-out Supervision rules for just RadOnc?
3) To clarify: you're saying that for as bad as the job market became, it would have been worse if not for Direct Supervision?
It's an interesting thought experiment. Obviously I can't really refute it in the same way you can't support it, but I see where you're coming from and don't think it's crazy.
4) Far and away the easiest thing to do is to just approach this from the other direction. Mandate minimal time-on-site. No need for any definitions of flexibilities, or exemptions, etc.
Why open the field up to the possibility of exploitation of a stupid rule when the people calling for it are still like "yeah, but i'm there 90%"?
"Open up the field to the possibility of exploitation" implies exploitation has not taken place.
I would argue the exploitation ship has long ago sailed. Cheap, abundant resident labor. PPS-exempt centers engaged in consolidation to make more PPS-exempt centers. 21C/GenesisCare docs in ASTRO/ABR leadership positions lobbying for policy which benefits freestanding centers while the majority of the field is hospital outpatient. The proliferation of unaccredited fellowship positions. And on and on and on.
At the end of the day, there is literally no regulation that any of us can dream up that won't, in some way, be circumvented. Further exploitation will occur.
Direct Supervision turned RadOnc into clock-punching technicians. Tele-RadOnc is already here, and has been here for awhile.
But all that aside, I'm very troubled by the behavior of the ASTRO leadership tonight.
We deserve better.