Every year, administrators of independent diagnostic testing facilities (IDTFs) scan the newly published Medicare Physician Fee Schedule (MPFS) for changes that affect their practices. But even with the rule in plain view, figuring out if there are any changes to existing protocol can be challenging.
When the Centers for Medicare and Medicaid Services (CMS) published its final fee schedule for 2008 last fall, the agency took the opportunity to modify 14 relatively new performance standards for IDTFs and create a new one. All went into play January 1 of this year, and are important for both physician and administrative IDTF staff to understand, according to W. Kenneth Davis Jr. of the law firm Katten Muchin Rosenman. Davis gave an overview of CMS' modifications at a recent Radiology Business Management Association (RBMA) meeting in San Francisco.
A new standard
The new standard CMS wrote addresses the definition of an IDTF: According to performance standard number 15, except for hospital-based and mobile IDTFs, a fixed-based IDTF does not include sharing a location, leasing or subleasing a location, or sharing diagnostic testing equipment with another Medicare-enrolled entity.
CMS is allowing a one-year transition period for IDTFs in this situation to change, Davis said.
But some particulars of standard 15 remain unclear. CMS did not provide guidance about what qualifies as a hospital-based IDTF. Sharing staff and "common areas," such as hallways, parking lots, and waiting rooms, isn't forbidden (although registration areas, file rooms, and back office areas aren't mentioned). Informally, according to Davis, CMS has said that the rule against sharing equipment is designed to keep IDTFs from leasing their equipment to other entities, but is not intended to prevent IDTFs from leasing equipment themselves.
Other standards CMS modified in the 2008 MPFS include the following:
| Standard | 2008 MPFS modification |
| 2 | Changes in ownership, location, general supervision, and adverse legal actions must be reported to Medicare within 30 calendar days of the change. All other changes to the enrollment application must be reported within 90 days. |
| 3 | Hotels and motels are not appropriate sites for an IDTF; those clinicians that provide services remotely are exempt from hand washing and adequate patient care accommodations rules. |
| 6 | An IDTFs liability insurance policy is no longer required to list the serial numbers of diagnostic equipment; mandatory $300,000 limit is per incident; an IDTF must clarify in writing any policy changes or cancellations. |
| 8 | IDTFs must keep documentation of a patient's written clinical complaint at the physical site of the IDTF. |
CMS also addressed supervision at IDTFs, explaining that the limitation on providing supervision to no more than three IDTF sites applies to both fixed and mobile sites, and removing the requirement that the "supervising physician is responsible for the overall operation and administration of the IDTFs." Some Medicare carriers have made local coverage decisions that require all levels of supervision to be performed by radiologists who are board-certified or board-eligible, Davis said.
To be an IDTF ... or not?
Even as performance standards for IDTFs shift, a trend toward pushing physician groups to identify as an IDTF is gaining momentum. At least one Medicare provider has decided that if a group practice bills for the technical component and the radiology group bills separately for the professional component, the practice must identify as an IDTF, Davis said.
Some owners are considering canceling their enrollment with Medicare as IDTFs, and re-enrolling in another category such as a diagnostic radiology group practice or clinic.
Although there's no rule against doing this, Medicare providers aren't familiar with the process, and most seem to be biased toward requiring diagnostic imaging facilities to be enrolled as IDTFs. In fact, some carriers are reviewing whether the imaging centers on their rolls that are owned and operated by physician groups should be IDTFs, according to Davis.
By Kate Madden Yee
AuntMinnie.com staff writer
April 8, 2008
Related Reading
CMS delays in-office self-referral decision with new MPFS rule, November 7, 2007
CMS publishes 2008 physician payment rule, November 4, 2007
CMS proposes hike in cardiac PET reimbursement, October 19, 2007
New CMS rules could add to radiology's reimbursement woes, August 1, 2007
CMS releases 2008 HOPPS proposed rule, July 19, 2007
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