Currently, Medicare Part B pays for imaging services pursuant to the physician professional cost component, the malpractice costs, and the practice expenses. Practice expenses are resources used in furnishing the services (i.e., rent, personnel costs, equipment costs, etc.). The OIG will review whether the Medicare payments for practice expenses “reflect…
On October 4, 2010, the OIG released its Work Plan for the FY of 2011. Throughout the week, we will be posting on various aspects of the Work Plan pertinent to our clients and our readers in the following areas: • Hospitals • Home Health Agencies • Hospices • Evaluation…
On September 28, the Office of Inspector General (OIG) posted Advisory Opinion 10-20 in which it analyzed another pre-authorization arrangement. This is the OIG’s third Advisory Opinion issued this year that favorably reviews the provision of free pre-authorization services to referral sources (please visit our September 9 and May 14…
The OIG released Advisory Opinion 10-13 on August 31, 2010, concerning a proposed-arrangement where a hospital would be providing pre-authorization services for diagnostic imaging. Requestor, a non-profit hospital, provides diagnostic imaging services to patients. Because many commercial insurers have begun requiring pre-authorization prior to covering diagnostic imaging services, the hospital…
Founding partner, Adrienne Dresevic, Esq. was quoted in Kaiser Health News on August 23, 2010 in an article on the recent regulations pertaining to physician disclosure requirements involving imaging machines. Dresevic often writes articles and speaks across the nation about the laws and policies surrounding imaging arrangements. For more information…
A bill introduced in the Senate on August 5, 2010 would set forth minimum credentialing standards for medical personnel who “perform or plan” medical imaging or radiation therapy procedures. The Consistency, Accuracy, Responsibility and Excellence (CARE) in Medical Imaging and Radiation Therapy Act, introduced by Sen. Harkin (D-IA) and Sen.…
Effective May 1, 2010, physicians, IDTFs and other Part B Suppliers furnishing Non-invasive Vascular Testing in Michigan must comply with new training and certification requirements. In part, the policy, as set forth in a new LCD, states: A. Training and Certification 1. The accuracy of non-invasive vascular diagnostic studies depends…
Effective March 15, 2010, pursuant to CMS’s update to the Medicare Claims Processing Manual addressing “Payment to Physician or Other Supplier for Diagnostic Tests Subject to the Anti-Markup Payment Limitation”, among other actions, The Centers for Medicare and Medicaid Services (“CMS”) has effectively eliminated an Independent Diagnostic Testing Facility’s (“IDTF’s”)…
Last week, the OIG released it’s Compendium of Unimplemented Recommendations that “consolidates significant unimplemented monetary and nonmonetary recommendations addressed to the Department of Health & Human Services (HHS) to provide information to interested parties about outstanding recommendations….” While these have not been implemented, it is something we want our clients…