Originally published by our colleagues at Tennessee Medical Association.
Last month, the Tennessee Board of Medical Examiners published a notice of several rule changes that may impact physicians. The Board will accept public written or in-person comments on the rules on September 22, 2026, at 1:00 PM Central in the Iris Conference Room, 665 Mainstream Dr., Nashville, 37243. Written comments may be submitted to Ms. Francine Baca-Chavez at the same address.
Remote supervision of imaging procedures. Radiologists should be aware that the Board is proposing a change to rules governing the supervision of contrast medium imaging procedures. Currently, supervision requires the on-site presence of the supervising physician. The proposed rule would allow supervision by remote telecommunication if certain conditions are met.
The Tennessee Radiologists Society petitioned for the rule. The rule would require at least one “qualified licensed practitioner” on premises to address a reaction or emergency. The rules define “qualified licensed practitioner.” Practices utilizing remote direct supervision would also be required to have protocols in accordance with guidelines established by the Center for Medicare and Medicaid Services, the American College of Radiology or other nationally recognized radiology accreditation organization.
Click here to access the proposed rule.
Advance Practice Registered Nurse Clinical Supervision Requirements. The Board is making housekeeping changes to its APRN clinical supervision rules. The first proposed change is to delete references in the rules to “supervision” and replace such references with “collaboration.” This would make the rules consistent with the language already in statute but does not make substantial changes to physician obligations.
The other major change proposed is the updating of the requirements for remote site visits. It is already in law that ten (10) of the annual remote site visits may be conducted by HIPAA-compliant electronic means rather than at the site of the clinic. The rule would finally make the rule language consistent with what has been in statute. There are no substantive changes to current statutory supervision requirements for physicians that are not already in law.
Click here to access the proposed rule.
Office-Based Surgery. Medical practices considering new level III office-based surgery suite certification or alterations to existing suites should carefully review proposed rules as substantial changes are proposed regarding level III office-based surgery certification. Changes reflect statutory changes moving oversight of office-based surgery from the Department of Health to the Health Facilities Commission, which conducts inspections.
The rule would increase the certification and renewal fees by nearly $800. New construction would have to be approved based on plans submitted to the Commission. Many extremely specific code requirements are set forth in the submitted rule. The rules go into minute detail as to requirements for almost every inch of the suite.
The effect of the rules is to virtually equate level III office-based surgery suites with ambulatory surgery centers. Developing new or altering level III suites will be much more expensive and time-consuming. It appears that the intent of the rules is to drive practices to establish ASTCs instead of level III suites since standards would almost be the same.
Click here to access the proposed rule.
