The Centers for Medicare & Medicaid Services (CMS) has finalized a permanent definition of ‘immediate availability’ for virtual direct supervision, effective January 1, 2026. This policy allows specialized physicians to meet supervision requirements via real-time, two-way audio and video telecommunications, transitioning from temporary pandemic-era flexibilities to a permanent regulatory standard. ContrastConnect has released a guide clarifying the distance and coverage implications of this definition to help healthcare providers maintain compliance.
More information is available at: https://www.contrast-connect.com/blog-post/cms-immediate-availability-definition-explained-meaning-distance-coverage-requirements-2026-update
Straightforward implementation is vital as the rule change impacts operational workflows and audit-ready documentation. The policy applies to office-based settings, including Independent Diagnostic Testing Facilities (IDTFs), for Level 2 diagnostic tests. However, services with 010 or 090 global surgery indicators—minor and major procedures—are explicitly excluded. According to the American College of Radiology’s December 2025 statement, virtual supervision is permissible when it aligns with federal and state laws and institutional policies.
Operational compliance requires specific technical infrastructure. Real-time, two-way audio and visual interactive technology is mandatory; audio-only communication fails to meet CMS requirements. The supervising practitioner must remain immediately available throughout the entire test to assist at any moment. Medicare regulations require documentation of supervision arrangements, so providers must establish protocols that demonstrate continuous availability and communication capacity.
State telemedicine laws and professional guidance impose additional compliance layers beyond federal standards. Healthcare providers must review state regulations and institutional policies regarding contrast media administration and adverse reaction management. Specialized radiologists should be consulted to ensure full compliance across all applicable regulatory frameworks.
This permanent policy allows healthcare organizations to expand diagnostic capacity in underserved markets. Virtual supervision removes geographic barriers and improves scheduling flexibility, particularly benefiting rural areas facing radiologist shortages. Organizations implementing compliant virtual supervision may see reduced patient wait times and improved staff efficiency.
ContrastConnect’s Distance & Coverage Guide serves as a resource for physician practices, IDTFs, and hospitals attempting to implement these protocols. Healthcare organizations can access the guide to ensure supervision arrangements meet federal standards while accommodating state and local requirements.
For more information, visit: https://www.contrast-connect.com/
Note: Information provided is for general guidance only and does not constitute medical, legal, or financial advice. Pricing estimates and regulatory requirements are current at the time of writing and subject to change. For personalized consultation on imaging center operations and virtual contrast supervision, contact ContrastConnect.
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