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National Policy & Legislation Tracker for Contrast Supervision
Stay updated on federal, state, and regulatory developments affecting virtual supervision, contrast administration, and scope of practice.
Policy Tracker
Policy Tracker
The American College of Radiology (ACR)
The American College of Radiology (ACR)
The ACR affirms that contrast-enhanced imaging can be performed with virtual direct supervision when trained personnel and emergency protocols are in place. It supports real-time audio-video communication as meeting federal expectations for physician availability.
The ACR affirms that contrast-enhanced imaging can be performed with virtual direct supervision when trained personnel and emergency protocols are in place. It supports real-time audio-video communication as meeting federal expectations for physician availability.
The American College of Radiology (ACR) sets the accreditation requirements that imaging centers must meet to safely administer contrast, including policies for physician supervision levels, technologist competencies, emergency preparedness, and reaction-management protocols.
These standards form the regulatory baseline many states and payors reference when evaluating compliance.
Tether Supervision is engineered to align with these accreditation expectations, providing real-time physician availability and documented workflows that support centers in maintaining ACR-compliant operations.
The American College of Radiology (ACR) sets the accreditation requirements that imaging centers must meet to safely administer contrast, including policies for physician supervision levels, technologist competencies, emergency preparedness, and reaction-management protocols.
These standards form the regulatory baseline many states and payors reference when evaluating compliance.
Tether Supervision is engineered to align with these accreditation expectations, providing real-time physician availability and documented workflows that support centers in maintaining ACR-compliant operations.
Updated Statement from Drugs and Contrast Media Committee
On June 12, 2025, the ACR Drugs and Contrast Media Committee released an updated supervision statement—superseding the February 2024 version—again affirming that direct supervision is required whenever contrast is administered. The update clarified that direct supervision may be performed either on-site or virtually by a physician through December 31, 2025, consistent with CMS’s definition of virtual “immediate availability.”
Virtual supervision was restricted, however: only physicians may provide it; multi-layer remote chains are not permitted; and bi-directional real-time audiovisual communication is mandatory. Requirements for on-site staffing were strengthened, mandating at least one licensed practitioner (in addition to the technologist) trained in patient assessment, medication administration, reaction differentiation, and emergency intervention. Qualified practitioners (including NP, PA, CNS) may supervise when allowed legally and must ensure timely physician consultation. The update emphasized that overall staffing must support rapid emergency response.
The statement also included a disclaimer that the policy does not create inflexible rules or requirements of practice and is not intended, nor should it be used, to establish a legal standard of care. The disclaimer also stated that the ultimate judgment regarding the propriety of any specific procedure or course of action must be made by the practitioner considering all the circumstances presented.
Updated Statement from Drugs and Contrast Media Committee
On June 12, 2025, the ACR Drugs and Contrast Media Committee released an updated supervision statement—superseding the February 2024 version—again affirming that direct supervision is required whenever contrast is administered. The update clarified that direct supervision may be performed either on-site or virtually by a physician through December 31, 2025, consistent with CMS’s definition of virtual “immediate availability.”
Virtual supervision was restricted, however: only physicians may provide it; multi-layer remote chains are not permitted; and bi-directional real-time audiovisual communication is mandatory. Requirements for on-site staffing were strengthened, mandating at least one licensed practitioner (in addition to the technologist) trained in patient assessment, medication administration, reaction differentiation, and emergency intervention. Qualified practitioners (including NP, PA, CNS) may supervise when allowed legally and must ensure timely physician consultation. The update emphasized that overall staffing must support rapid emergency response.
The statement also included a disclaimer that the policy does not create inflexible rules or requirements of practice and is not intended, nor should it be used, to establish a legal standard of care. The disclaimer also stated that the ultimate judgment regarding the propriety of any specific procedure or course of action must be made by the practitioner considering all the circumstances presented.
Updated Statement from Drugs and Contrast Media Committee
On June 12, 2025, the ACR Drugs and Contrast Media Committee released an updated supervision statement—superseding the February 2024 version—again affirming that direct supervision is required whenever contrast is administered. The update clarified that direct supervision may be performed either on-site or virtually by a physician through December 31, 2025, consistent with CMS’s definition of virtual “immediate availability.”
Virtual supervision was restricted, however: only physicians may provide it; multi-layer remote chains are not permitted; and bi-directional real-time audiovisual communication is mandatory. Requirements for on-site staffing were strengthened, mandating at least one licensed practitioner (in addition to the technologist) trained in patient assessment, medication administration, reaction differentiation, and emergency intervention. Qualified practitioners (including NP, PA, CNS) may supervise when allowed legally and must ensure timely physician consultation. The update emphasized that overall staffing must support rapid emergency response.
The statement also included a disclaimer that the policy does not create inflexible rules or requirements of practice and is not intended, nor should it be used, to establish a legal standard of care. The disclaimer also stated that the ultimate judgment regarding the propriety of any specific procedure or course of action must be made by the practitioner considering all the circumstances presented.
ACR Guidance on Direct Supervision for Contrast Studies
On September 23, 2024, the ACR issued new guidance advising sites to return to on-site direct supervision for CT and MR accreditation following the expiration of federal COVID-19 PHE flexibilities.
The guidance instructed imaging centers to follow standard accreditation requirements for contrast administration and reaction management and referenced updated supervising-physician requirements affecting MRI, breast MRI, and CT programs.
ACR Guidance on Direct Supervision for Contrast Studies
On September 23, 2024, the ACR issued new guidance advising sites to return to on-site direct supervision for CT and MR accreditation following the expiration of federal COVID-19 PHE flexibilities.
The guidance instructed imaging centers to follow standard accreditation requirements for contrast administration and reaction management and referenced updated supervising-physician requirements affecting MRI, breast MRI, and CT programs.
ACR Guidance on Direct Supervision for Contrast Studies
On September 23, 2024, the ACR issued new guidance advising sites to return to on-site direct supervision for CT and MR accreditation following the expiration of federal COVID-19 PHE flexibilities.
The guidance instructed imaging centers to follow standard accreditation requirements for contrast administration and reaction management and referenced updated supervising-physician requirements affecting MRI, breast MRI, and CT programs.
Initial ACR Drugs and Contrast Media Committee Statement on Supervision
On February 29, 2024, the ACR Drugs and Contrast Media Committee released its initial statement on supervision of contrast material administration. The statement reaffirmed that direct supervision is required for all contrast administration and post-administration monitoring but formally introduced the option for virtual/remote direct supervision by a physician when a qualified on-site professional is present. The on-site provider must be trained in patient assessment, reaction recognition, emergency medication administration (including IV epinephrine), and real-time consultation with the supervising physician via audio-visual communication. The update also clarified that NPs, PAs, and CNSs may participate consistent with state law and institutional policy.
Initial ACR Drugs and Contrast Media Committee Statement on Supervision
On February 29, 2024, the ACR Drugs and Contrast Media Committee released its initial statement on supervision of contrast material administration. The statement reaffirmed that direct supervision is required for all contrast administration and post-administration monitoring but formally introduced the option for virtual/remote direct supervision by a physician when a qualified on-site professional is present. The on-site provider must be trained in patient assessment, reaction recognition, emergency medication administration (including IV epinephrine), and real-time consultation with the supervising physician via audio-visual communication. The update also clarified that NPs, PAs, and CNSs may participate consistent with state law and institutional policy.
Initial ACR Drugs and Contrast Media Committee Statement on Supervision
On February 29, 2024, the ACR Drugs and Contrast Media Committee released its initial statement on supervision of contrast material administration. The statement reaffirmed that direct supervision is required for all contrast administration and post-administration monitoring but formally introduced the option for virtual/remote direct supervision by a physician when a qualified on-site professional is present. The on-site provider must be trained in patient assessment, reaction recognition, emergency medication administration (including IV epinephrine), and real-time consultation with the supervising physician via audio-visual communication. The update also clarified that NPs, PAs, and CNSs may participate consistent with state law and institutional policy.
ACR–SPR Practice Parameter for the Use of Intravascular Contrast Media
In 2023, the ACR–SPR updated its Practice Parameter for the Use of Intravascular Contrast Media to clarify who may supervise IV contrast administration and what competencies are required. The parameter confirms that a radiologist (MD/DO) may directly supervise intravenous contrast administration. It also states that, when working under the general supervision of a radiologist, non-radiologist physicians, advanced practice providers (NPs and PAs), and registered nurses using a symptom- and sign-driven treatment algorithm may provide direct supervision as well.
Any provider performing direct supervision must be trained and regularly demonstrate competence in managing acute hypersensitivity and physiologic reactions; administering oxygen, antihistamines, IV fluids, beta-agonists, epinephrine, and other interventions; knowing when and how to activate emergency response systems; and maintaining Basic Life Support (BLS) certification. The supervising provider must be immediately available to offer assistance throughout the procedure, though not necessarily inside the procedure room. At least one individual capable of recognizing adverse reactions must be present in the room or adjacent control area to observe the patient during and immediately after the injection and to summon medical help if needed.
ACR–SPR Practice Parameter for the Use of Intravascular Contrast Media
In 2023, the ACR–SPR updated its Practice Parameter for the Use of Intravascular Contrast Media to clarify who may supervise IV contrast administration and what competencies are required. The parameter confirms that a radiologist (MD/DO) may directly supervise intravenous contrast administration. It also states that, when working under the general supervision of a radiologist, non-radiologist physicians, advanced practice providers (NPs and PAs), and registered nurses using a symptom- and sign-driven treatment algorithm may provide direct supervision as well.
Any provider performing direct supervision must be trained and regularly demonstrate competence in managing acute hypersensitivity and physiologic reactions; administering oxygen, antihistamines, IV fluids, beta-agonists, epinephrine, and other interventions; knowing when and how to activate emergency response systems; and maintaining Basic Life Support (BLS) certification. The supervising provider must be immediately available to offer assistance throughout the procedure, though not necessarily inside the procedure room. At least one individual capable of recognizing adverse reactions must be present in the room or adjacent control area to observe the patient during and immediately after the injection and to summon medical help if needed.
ACR–SPR Practice Parameter for the Use of Intravascular Contrast Media
In 2023, the ACR–SPR updated its Practice Parameter for the Use of Intravascular Contrast Media to clarify who may supervise IV contrast administration and what competencies are required. The parameter confirms that a radiologist (MD/DO) may directly supervise intravenous contrast administration. It also states that, when working under the general supervision of a radiologist, non-radiologist physicians, advanced practice providers (NPs and PAs), and registered nurses using a symptom- and sign-driven treatment algorithm may provide direct supervision as well.
Any provider performing direct supervision must be trained and regularly demonstrate competence in managing acute hypersensitivity and physiologic reactions; administering oxygen, antihistamines, IV fluids, beta-agonists, epinephrine, and other interventions; knowing when and how to activate emergency response systems; and maintaining Basic Life Support (BLS) certification. The supervising provider must be immediately available to offer assistance throughout the procedure, though not necessarily inside the procedure room. At least one individual capable of recognizing adverse reactions must be present in the room or adjacent control area to observe the patient during and immediately after the injection and to summon medical help if needed.
ACR CT and MRI Accreditation Program Personnel Requirement Update
In August 2022, the ACR announced changes to its CT and MRI Accreditation Program, allowing qualified non-radiologist physicians (MD/DO) as well as non-physician practitioners—including nurse practitioners, physician assistants, and clinical nurse specialists—to serve as direct supervisors of contrast administration for accreditation purposes. This change aligned accreditation rules with CMS’s earlier recognition of mid-level practitioners and represented a major operational shift away from radiologist-only direct supervision in many outpatient and hospital settings.
ACR CT and MRI Accreditation Program Personnel Requirement Update
In August 2022, the ACR announced changes to its CT and MRI Accreditation Program, allowing qualified non-radiologist physicians (MD/DO) as well as non-physician practitioners—including nurse practitioners, physician assistants, and clinical nurse specialists—to serve as direct supervisors of contrast administration for accreditation purposes. This change aligned accreditation rules with CMS’s earlier recognition of mid-level practitioners and represented a major operational shift away from radiologist-only direct supervision in many outpatient and hospital settings.
ACR CT and MRI Accreditation Program Personnel Requirement Update
In August 2022, the ACR announced changes to its CT and MRI Accreditation Program, allowing qualified non-radiologist physicians (MD/DO) as well as non-physician practitioners—including nurse practitioners, physician assistants, and clinical nurse specialists—to serve as direct supervisors of contrast administration for accreditation purposes. This change aligned accreditation rules with CMS’s earlier recognition of mid-level practitioners and represented a major operational shift away from radiologist-only direct supervision in many outpatient and hospital settings.
Policy Tracker
Policy Tracker
Centers for Medicare & Medicaid Services (CMS)
Centers for Medicare & Medicaid Services (CMS)
Under current CMS policy, direct supervision may be met through real-time, two-way audio-video communication when qualified on-site personnel and emergency-response protocols are in place
Under current CMS policy, direct supervision may be met through real-time, two-way audio-video communication when qualified on-site personnel and emergency-response protocols are in place
CMS defines the federal supervision standards that govern how contrast-enhanced imaging may be performed in both office-based and hospital outpatient settings. CMS’s definitions of direct, general, and personal supervision drive how states, accrediting bodies, and payors interpret compliance.
These federal standards shape credentialing expectations, staffing models, and reimbursement eligibility for contrast-enhanced imaging.
Tether Supervision is built to align with CMS requirements, providing real-time physician availability and structured workflows that help imaging centers maintain compliance across outpatient and hospital settings.
CMS defines the federal supervision standards that govern how contrast-enhanced imaging may be performed in both office-based and hospital outpatient settings. CMS’s definitions of direct, general, and personal supervision drive how states, accrediting bodies, and payors interpret compliance.
These federal standards shape credentialing expectations, staffing models, and reimbursement eligibility for contrast-enhanced imaging.
Tether Supervision is built to align with CMS requirements, providing real-time physician availability and structured workflows that help imaging centers maintain compliance across outpatient and hospital settings.
CY 2026 HOPPS Final Rule
CMS finalized its 2026 hospital outpatient policies by reaffirming general supervision as the default requirement for most diagnostic imaging services performed in Hospital Outpatient Departments (HOPDs), including CT and MRI with contrast. Under HOPPS, contrast administration is treated as part of the diagnostic service, and CMS determined that general supervision—rather than on-site direct supervision—is appropriate when hospitals maintain trained personnel, emergency protocols, and rapid physician-consultation pathways. Facilities may still choose to require higher supervision levels for higher-risk scenarios, but CMS concluded that the general-supervision framework provides sufficient safeguards for routine contrast-enhanced imaging. This framework remains the controlling federal standard for hospital outpatient imaging beginning in 2026.
CY 2026 HOPPS Final Rule
CMS finalized its 2026 hospital outpatient policies by reaffirming general supervision as the default requirement for most diagnostic imaging services performed in Hospital Outpatient Departments (HOPDs), including CT and MRI with contrast. Under HOPPS, contrast administration is treated as part of the diagnostic service, and CMS determined that general supervision—rather than on-site direct supervision—is appropriate when hospitals maintain trained personnel, emergency protocols, and rapid physician-consultation pathways. Facilities may still choose to require higher supervision levels for higher-risk scenarios, but CMS concluded that the general-supervision framework provides sufficient safeguards for routine contrast-enhanced imaging. This framework remains the controlling federal standard for hospital outpatient imaging beginning in 2026.
CY 2026 HOPPS Final Rule
CMS finalized its 2026 hospital outpatient policies by reaffirming general supervision as the default requirement for most diagnostic imaging services performed in Hospital Outpatient Departments (HOPDs), including CT and MRI with contrast. Under HOPPS, contrast administration is treated as part of the diagnostic service, and CMS determined that general supervision—rather than on-site direct supervision—is appropriate when hospitals maintain trained personnel, emergency protocols, and rapid physician-consultation pathways. Facilities may still choose to require higher supervision levels for higher-risk scenarios, but CMS concluded that the general-supervision framework provides sufficient safeguards for routine contrast-enhanced imaging. This framework remains the controlling federal standard for hospital outpatient imaging beginning in 2026.
CY 2026 PFS Final Rule (CMS-1832-F)
CMS issued the controlling policy for 2026 and beyond, permanently redefining “direct supervision” to include immediate availability via real-time audio-video telecommunications technology. Effective January 1, 2026, virtual direct supervision becomes a standing federal rule for diagnostic tests under §410.32 and incident-to services under §410.26. Physicians and qualified NPPs may serve as supervising practitioners where permitted by state law. CMS concluded that virtual availability provides sufficient patient safety for most services, while allowing facilities to require in-person supervision for higher-risk contrast cases. Parallel permanent policies were established for teaching settings, RHCs/FQHCs, and several other programs.
CY 2026 PFS Final Rule (CMS-1832-F)
CMS issued the controlling policy for 2026 and beyond, permanently redefining “direct supervision” to include immediate availability via real-time audio-video telecommunications technology. Effective January 1, 2026, virtual direct supervision becomes a standing federal rule for diagnostic tests under §410.32 and incident-to services under §410.26. Physicians and qualified NPPs may serve as supervising practitioners where permitted by state law. CMS concluded that virtual availability provides sufficient patient safety for most services, while allowing facilities to require in-person supervision for higher-risk contrast cases. Parallel permanent policies were established for teaching settings, RHCs/FQHCs, and several other programs.
CY 2026 PFS Final Rule (CMS-1832-F)
CMS issued the controlling policy for 2026 and beyond, permanently redefining “direct supervision” to include immediate availability via real-time audio-video telecommunications technology. Effective January 1, 2026, virtual direct supervision becomes a standing federal rule for diagnostic tests under §410.32 and incident-to services under §410.26. Physicians and qualified NPPs may serve as supervising practitioners where permitted by state law. CMS concluded that virtual availability provides sufficient patient safety for most services, while allowing facilities to require in-person supervision for higher-risk contrast cases. Parallel permanent policies were established for teaching settings, RHCs/FQHCs, and several other programs.
CY 2025 PFS Final Rule (CMS-1807-F)
CMS extended virtual direct supervision one final time, through December 31, 2025. The agency declined to adopt a permanent policy in this rulemaking, noting that more evidence was needed regarding higher-risk scenarios, including contrast reactions. The rule reaffirmed NPP authority to supervise diagnostic tests and reiterated that real-time, two-way interactive technology—physician or NPP—constitutes virtual presence.
CY 2025 PFS Final Rule (CMS-1807-F)
CMS extended virtual direct supervision one final time, through December 31, 2025. The agency declined to adopt a permanent policy in this rulemaking, noting that more evidence was needed regarding higher-risk scenarios, including contrast reactions. The rule reaffirmed NPP authority to supervise diagnostic tests and reiterated that real-time, two-way interactive technology—physician or NPP—constitutes virtual presence.
CY 2025 PFS Final Rule (CMS-1807-F)
CMS extended virtual direct supervision one final time, through December 31, 2025. The agency declined to adopt a permanent policy in this rulemaking, noting that more evidence was needed regarding higher-risk scenarios, including contrast reactions. The rule reaffirmed NPP authority to supervise diagnostic tests and reiterated that real-time, two-way interactive technology—physician or NPP—constitutes virtual presence.
CY 2024 PFS Final Rule
The CY 2024 Final Rule again extended the virtual definition of direct supervision through December 31, 2024, maintaining operational continuity for imaging centers and clarifying CMS’s intent to evaluate long-term policy options.
CY 2024 PFS Final Rule
The CY 2024 Final Rule again extended the virtual definition of direct supervision through December 31, 2024, maintaining operational continuity for imaging centers and clarifying CMS’s intent to evaluate long-term policy options.
CY 2024 PFS Final Rule
The CY 2024 Final Rule again extended the virtual definition of direct supervision through December 31, 2024, maintaining operational continuity for imaging centers and clarifying CMS’s intent to evaluate long-term policy options.
CY 2022 and CY 2023 PFS Final Rules
CMS extended virtual direct supervision through additional rule cycles to collect further safety and operational data. The CY 2023 Final Rule explicitly confirmed the continuation of virtual supervision through December 31, 2023, preserving real-time audio-video oversight as acceptable for services that normally require direct supervision.
CY 2022 and CY 2023 PFS Final Rules
CMS extended virtual direct supervision through additional rule cycles to collect further safety and operational data. The CY 2023 Final Rule explicitly confirmed the continuation of virtual supervision through December 31, 2023, preserving real-time audio-video oversight as acceptable for services that normally require direct supervision.
CY 2022 and CY 2023 PFS Final Rules
CMS extended virtual direct supervision through additional rule cycles to collect further safety and operational data. The CY 2023 Final Rule explicitly confirmed the continuation of virtual supervision through December 31, 2023, preserving real-time audio-video oversight as acceptable for services that normally require direct supervision.
CY 2021 PFS Final Rule (CMS-1734-F)
The 2021 PFS Final Rule extended virtual direct supervision through the end of the calendar year in which the Public Health Emergency ended and clarified that the policy applied in both teaching and non-teaching settings. In the same rulemaking cycle, CMS also implemented a major structural change by allowing qualified non-physician practitioners—NPs, PAs, CNSs, and others authorized under state law—to supervise diagnostic tests. This expansion directly enabled NPPs to provide direct supervision for contrast administration in physician offices, IDTFs, and Part B outpatient environments, significantly increasing workforce flexibility.
CY 2021 PFS Final Rule (CMS-1734-F)
The 2021 PFS Final Rule extended virtual direct supervision through the end of the calendar year in which the Public Health Emergency ended and clarified that the policy applied in both teaching and non-teaching settings. In the same rulemaking cycle, CMS also implemented a major structural change by allowing qualified non-physician practitioners—NPs, PAs, CNSs, and others authorized under state law—to supervise diagnostic tests. This expansion directly enabled NPPs to provide direct supervision for contrast administration in physician offices, IDTFs, and Part B outpatient environments, significantly increasing workforce flexibility.
CY 2021 PFS Final Rule (CMS-1734-F)
The 2021 PFS Final Rule extended virtual direct supervision through the end of the calendar year in which the Public Health Emergency ended and clarified that the policy applied in both teaching and non-teaching settings. In the same rulemaking cycle, CMS also implemented a major structural change by allowing qualified non-physician practitioners—NPs, PAs, CNSs, and others authorized under state law—to supervise diagnostic tests. This expansion directly enabled NPPs to provide direct supervision for contrast administration in physician offices, IDTFs, and Part B outpatient environments, significantly increasing workforce flexibility.
COVID-19 Interim Final Rule (CMS-5531-IFC)
CMS issued an Interim Final Rule (retroactive to March 1, 2020) temporarily redefining “direct supervision” to include virtual presence through real-time, two-way audio-video communication. This flexibility applied to all services requiring direct or personal supervision, including diagnostic tests with contrast, and was designed to reduce infection risk while maintaining immediate clinical availability of supervising practitioners.
COVID-19 Interim Final Rule (CMS-5531-IFC)
CMS issued an Interim Final Rule (retroactive to March 1, 2020) temporarily redefining “direct supervision” to include virtual presence through real-time, two-way audio-video communication. This flexibility applied to all services requiring direct or personal supervision, including diagnostic tests with contrast, and was designed to reduce infection risk while maintaining immediate clinical availability of supervising practitioners.
COVID-19 Interim Final Rule (CMS-5531-IFC)
CMS issued an Interim Final Rule (retroactive to March 1, 2020) temporarily redefining “direct supervision” to include virtual presence through real-time, two-way audio-video communication. This flexibility applied to all services requiring direct or personal supervision, including diagnostic tests with contrast, and was designed to reduce infection risk while maintaining immediate clinical availability of supervising practitioners.
CMS Diagnostic Test Supervision Rules Defined (42 CFR §410.32(b); MBPM Ch. 15 §80)
CMS originally defined three levels of supervision—general, direct, and personal—and required that direct supervision be furnished by a physician who was physically present and “immediately available” within the office suite. Many diagnostic tests involving IV contrast, including CT and MRI with contrast, required direct supervision, and the requirement applied across the full service: contrast administration, patient monitoring, and reaction management. In the hospital outpatient setting, radiology services generally fell under general supervision, but contrast drug administration could still trigger direct-supervision requirements depending on the study and clinical context.
CMS Diagnostic Test Supervision Rules Defined (42 CFR §410.32(b); MBPM Ch. 15 §80)
CMS originally defined three levels of supervision—general, direct, and personal—and required that direct supervision be furnished by a physician who was physically present and “immediately available” within the office suite. Many diagnostic tests involving IV contrast, including CT and MRI with contrast, required direct supervision, and the requirement applied across the full service: contrast administration, patient monitoring, and reaction management. In the hospital outpatient setting, radiology services generally fell under general supervision, but contrast drug administration could still trigger direct-supervision requirements depending on the study and clinical context.
CMS Diagnostic Test Supervision Rules Defined (42 CFR §410.32(b); MBPM Ch. 15 §80)
CMS originally defined three levels of supervision—general, direct, and personal—and required that direct supervision be furnished by a physician who was physically present and “immediately available” within the office suite. Many diagnostic tests involving IV contrast, including CT and MRI with contrast, required direct supervision, and the requirement applied across the full service: contrast administration, patient monitoring, and reaction management. In the hospital outpatient setting, radiology services generally fell under general supervision, but contrast drug administration could still trigger direct-supervision requirements depending on the study and clinical context.