Radiology Stark Healthcare Rules and IDTF

IDTF status is one the things you have to be concerned about under new Stark healthcare rules. There are two types of parties have been concerned about whether they have to have to be separately certified as IDTF in order to provide radiology services. It was thought that physicians who have like CT scan in their office might have to get separate IDTF status. Physicians are already identified as Medicare providers. It would be another status that they'd have to get.

Right now as a result of the last go around, Medicare is saying, “No, you don't have to do that. You're probably going to have to get accreditation in a few years but right now we're not going to require you, doctor to get separate IDTF status.”

Now, on the other hand, mobile companies that provide equipment or provide staff to perform tests are required at least under the healthcare guidelines  to be an IDTF provider. Originally, these are just seen as suppliers. They're just vendors. There would be really no reason for them to get the status. But Medicare was saying in their rule, “Hey, yes, you need to have the status. And you need to be Medicare providers.”

Our expert clarified it in one of the Stark audio conferencesthat the other area that was covered by these final rules are IDTF standards themselves, that if you are already an IDTF you were trying to limit this activity of this wholesale/retail arrangements. And so, we are telling you IDTF to maintain your status. As a Medicare provider, you cannot have any further shared locations with another Medicare provider. If you have them now you have until October of this year to unwind them.

You're not supposed to lease or sub-lease to another Medicare provider that's trying to deal with the issue of block lease nor are you supposed to share diagnostic test equipment. You can share non-clinical things like appointment staff or waiting rooms and so forth but anything related to the diagnostic equipment or the sharing of location, you know, that is clinical or used for testing, that can't be done. That has to be unwind. So basically it's saying, you know, you're only have to meet certain conditions of participation but you also can have certain deals because if you have these deals, we're going to take away your status.

The last thing is this issue of supervision. Remember that supervision is a specific term with respect to radiology. There's three types of supervision to ensure medical compliance. There's general supervision which many tests are operated under which is to have a doctor just available. It doesn't actually have to be even in the suite or in the building. Or you have direct supervision which requires the doctor to be there. Or you have personal supervision which requires the doctor not only to be in the office but to be at the, you know, the service that's being rendered, to be at the CT machine or whatever.

Those supervision requirements again are dictated by Medicare guidelines. And you can go online again and find the Excel sheet that gives you that information. But the point under Stark is that you need to have the right level of supervision of the techs that's performing the service in order to rely on that in-office ancillary exceptions. So, knowing the proper supervision level is critical in order to determine whether or not you've got the exception or not.

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