decisionhealth Newsletters, Coder Pink Sheets - 2007 Issue 8 (August)
CMS considers tightening PT/OT in-office rules
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Article Overview
This article explains several policy areas CMS was reviewing in the 2008 proposed Medicare physician fee schedule. It focuses on possible changes affecting in-office physical therapy and occupational therapy, the anti-markup rule for diagnostic services, and other Stark-related arrangements involving diagnostic imaging and independent diagnostic testing facilities. It is relevant to physician practices, therapists, imaging groups, hospital-based arrangements, and compliance professionals following Medicare billing and self-referral policy.
Why This Topic Matters
The topic matters because even proposed Medicare policy shifts can affect how physician groups structure ancillary services, imaging relationships, and compliance strategies. Practices that furnish therapy or diagnostic services need to understand the scope of the rules being reviewed and whether public comments may influence the final policy.
Article Sections
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PT/OT in-office rules
Discusses CMS review of the in-office ancillary exception under Stark and the broader policy context for physician-provided therapy services. It also addresses the comment process and prior regulatory changes affecting therapy services furnished in physician offices.
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Anti-markup applied to professional component
Summarizes the proposed expansion of Medicare’s anti-markup policy beyond the technical component to additional diagnostic service billing situations. The section also describes how contracted diagnostic service arrangements are part of the review.
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Other rules that CMS is proposing to change
Covers additional Stark and Medicare policy topics under consideration, including certain hospital-physician diagnostic arrangements, per-click leasing concepts, and changes affecting independent diagnostic testing facility requirements.
What You Will Learn
- Which Medicare policy areas CMS was considering revising in the 2008 proposed physician fee schedule
- How the article frames the impact of Stark self-referral policy on physician therapy and diagnostic service arrangements
- What kinds of diagnostic imaging and testing relationships were being discussed in the proposed changes
- Why comments from affected provider groups were seen as important
Who Should Read This
- Physician practices
- Orthopedic groups
- Physical therapists
- Occupational therapists
- Radiology and imaging practices
- Compliance and reimbursement professionals
- Healthcare attorneys and consultants
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