Compliance Officers' Forum

  • 1.  CY 2026 Physician Fee Schedule and Quality Payment Program Final Rule

    Posted 29 days ago

    Hello, 

    Under the "Virtual Supervision of Residents Providing Telehealth in All Trainings" in the 2026 PFS final rule, it states that virtual presence in all teaching settings, only in clinical instances when the service is a 3-way telehealth visit, with the teaching physician, resident, and patient in different locations.

    After reading the finalization, does this mean that when the resident and patient are in the same location with the teaching physician present remotely, it no longer meets the supervision requirements?

    Does anyone interpret this differently and can offer clarification?

    Thank you!

    Robyn Heckman

    University of Utah



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    Robyn Heckman
    Regulatory Compliance Manager
    University of Utah Health System
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  • 2.  RE: CY 2026 Physician Fee Schedule and Quality Payment Program Final Rule

    Posted 24 days ago

    This does read the way you're concerned about, and I'm interested whether others read it the same way. Previously as long as all three providers were "virtual" it was ok, whether or not they were in the same location. If "different location" is a new criteria, then we'd need to understand what different locations means. Can the resident be in a work room or visit room, while the TP is in their office for instance?



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    Mia London
    Director, Education, Risk, and Investigation
    UChicago Medicine
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    Original Message