Tom Greeson

So when does the clock start ticking on the 60-day Medicare overpayment refund requirement?

Presentation of radiology practice - hospital integration models and best practices.

Imaging centers enrolled in the Medicare program as Independent Diagnostic Testing Facilities, or IDTFs, face a growing number of challenges. For years IDTFs have been subject to a specific set of rules that are more restrictive than those applied to similar imaging centers enrolled in the Medicare program as physician offices (which are sometimes referred to as radiology clinics). For example, IDTFs are prohibited from sharing space with another Medicare provider, subject to compliance… Show more

Imaging centers enrolled in the Medicare program as Independent Diagnostic Testing Facilities, or IDTFs, face a growing number of challenges. For years IDTFs have been subject to a specific set of rules that are more restrictive than those applied to similar imaging centers enrolled in the Medicare program as physician offices (which are sometimes referred to as radiology clinics). For example, IDTFs are prohibited from sharing space with another Medicare provider, subject to compliance surveys, and required to disclose and update details of their operations in the Medicare enrollment applications (the CMS 855B form). Show less

Among the many provisions of the Patient Protection and Affordable Care Act (PPACA) designed to expand access to health insurance in the United States, two significant components have engaged public policymakers in the Commonwealth of Virginia: Medicaid expansion and the question of the state operating an insurance exchange.

On October 11, 2012, CMS published yet another version of its guidance on place-of-service codes for the professional and technical components of diagnostic tests. The guidance was first issued as transmittal 2561 on September 28, but that was rescinded and replaced (due to preimplementation contact-information changes) by transmittal 2563.1 It revises the instructions set forth in chapter 13 of the CMS manual system for Medicare claims processing. This transmittal is the latest in a series of… Show more

On October 11, 2012, CMS published yet another version of its guidance on place-of-service codes for the professional and technical components of diagnostic tests. The guidance was first issued as transmittal 2561 on September 28, but that was rescinded and replaced (due to preimplementation contact-information changes) by transmittal 2563.1 It revises the instructions set forth in chapter 13 of the CMS manual system for Medicare claims processing. This transmittal is the latest in a series of transmittals that began surfacing in 2009 addressing the place-of-service codes. Show less

While it may make good business sense for an imaging center or radiology practice to provide and pay for software upgrades necessary for the RIS/PACS to interface with the EHR or to install hardware, such as viewing stations, in the ordering physician’s office, these types of arrangements can raise significant regulatory issues. Federal and state laws prohibit radiologists and imaging centers from offering referring physicians something of value in return for ordering diagnostic tests. Because… Show more

While it may make good business sense for an imaging center or radiology practice to provide and pay for software upgrades necessary for the RIS/PACS to interface with the EHR or to install hardware, such as viewing stations, in the ordering physician’s office, these types of arrangements can raise significant regulatory issues. Federal and state laws prohibit radiologists and imaging centers from offering referring physicians something of value in return for ordering diagnostic tests. Because software upgrades and computer hardware provide real value to ordering physicians, these types of arrangements should be carefully considered under the relevant federal and state law.
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In a final rule published April 27, 2012, CMS has revised the ordering and documentation requirements for imaging services in several ways that are favorable to the radiology community.

Over the past several years, we have worked with an increasing number of clients who have been considering whether to restructure or sell their interest in their free-standing imaging centers.  Partly driven by decreased reimbursement for free-standing imaging service and partly driven by hospital interest in acquiring centers, we have recently worked with groups who have sold their ownership interests in imaging centers to the hospital where they practice.

The article describes the Medicare coverage and payment rules for working with radiologist assistants in hospital and nonhospital settings for both diagnostic testing and surgical or invasive procedures. The article also includes a summary of the current Medicare supervision requirements for a diagnostic test on the basis of the place of service: hospital, physician office, or independent diagnostic testing facility.

Many diagnostic radiology groups around the country have robust interventional radiology practices that provide minimally invasive procedures using imaging for guidance, such as angiography, angioplasty, biopsy, stenting, cryotherapy, and embolization. Because many interventional radiologists practice clinically, as treating physicians, and may order diagnostic radiology and ultrasound tests as part of their practice, they sometime refer Medicare and Medicaid patients to the radiology group's… Show more

Many diagnostic radiology groups around the country have robust interventional radiology practices that provide minimally invasive procedures using imaging for guidance, such as angiography, angioplasty, biopsy, stenting, cryotherapy, and embolization. Because many interventional radiologists practice clinically, as treating physicians, and may order diagnostic radiology and ultrasound tests as part of their practice, they sometime refer Medicare and Medicaid patients to the radiology group's imaging center. When an interventional radiologist holds an ownership interest in the imaging center, directly or indirectly through the group, the federal physician self-referral law (commonly referred to as the "Stark Law") requires that the interventional radiologist's financial interest fit within an exception to the general prohibition on self-referrals. Show less