I am sure I’m explaining something here many already understand or know.
Based on observing the conversations around this point for many years, I suspect the number of people who understand this point is actually very, very low.
(but yeah, they're probably all on SDN, lol)
Regardless, I don't think this has EVER been tested in any case or challenged anywhere in any official capacity.
But, I've always found this super weird:
For the IGRT code you're talking about (77014 off the top of my head), the "02 - Direct Supervision" is only for TC
Both the global AND the professional carry "09 - Does Not Apply".
Scrolling through the CPT codes, this breakdown seems really uncommon (obviously I haven't meticulously examined ALL codes, though).
1) What was the point of that?
2) Is anyone out there ever ONLY dropping 77014-TC? Seems unlikely, post-2015 bundle.
3) If both the global and professional have the 09 - Does Not Apply, why would anyone make the inductive leap the Direct Supervision is required?
Now, to be clear: I know exactly why Ron and ASTRO think that.
Taking that crew and their conflicts of interest aside, I'm asking in a vacuum, as in, can anyone construct an unbiased argument?