In recent years, the diagnostic imaging services industry has been intensively scrutinized by the federal government, as evidenced by heightened regulatory action targeting certain diagnostic imaging arrangements, such as changes to the federal Stark Law (that restrict the flexibility of structuring diagnostic imaging arrangements), expansion of the federal anti-markup prohibition, changes to the independent diagnostic testing facility (IDTF) performance standards, and implementation of payment changes related to the way imaging services are paid under the physician fee schedule. Industry stakeholders should anticipate, and be attentive to, future regulatory changes, as the Centers for Medicare and Medicaid Services (CMS) is expected to continue to focus on areas such as diagnostic imaging, which it believes are vulnerable to patient and program abuse, and which is among the fastest growing set of services paid for under Medicare Part B physician fee schedule.
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For more information, please call Adrienne Dresevic, Esq. or Carey F. Kalmowitz, Esq. at (248) 996-8510 or visit The HLP website.