Clarification on Services Provided Outside the United States

Clarification on Services Provided Outside the United States The Centers for Medicare and Medicaid Services provided clarification in Transmittal 66 (February 23, 2007) that payment may not be made for a medical service (or portion of it) that was subcontracted to another provider or supplier outside of the United States. The transmittal described that Medicare law Section 1862 (a) (4) of the Social Security Act excludes payments for services furnished outside of the United States. Furthermore, the transmittal provides the exceptions to the foreign exclusion rule. The attachment of the transmittal further clarifies that payment should not be made...

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Note:  The following article synopsis was NOT provided by the AMA. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains a CMS clarification affecting Medicare coverage and payment when part of a service is furnished outside the United States. It is relevant to coders, billers, compliance staff, and radiology practices that need to understand the scope of the foreign-service exclusion and the associated transmittal guidance. The article also points readers to the underlying CMS transmittal and frames the issue in a radiology context.

Why This Topic Matters

Organizations that bill Medicare need to know when services performed, interpreted, or subcontracted outside the United States may fall outside payment rules. Understanding this guidance helps support compliance review, claim processing, and documentation practices.

Article Sections

  1. Clarification on Services Provided Outside the United States

    Overview of CMS clarification regarding Medicare payment limitations for services associated with work performed outside the United States. The section frames the foreign-service exclusion and its relevance to covered services.

What You Will Learn

  • How CMS addressed Medicare payment for services associated with work performed outside the United States.
  • What general types of foreign-service exclusions and exceptions are referenced in the guidance.
  • Why this clarification is relevant to radiology-related services and compliance review.
  • Where to find the referenced CMS transmittal for additional context.

Who Should Read This

  • Medical coders
  • Medical billers
  • Compliance staff
  • Radiology practices
  • Revenue cycle professionals
  • Medicare providers

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