decisionhealth Newsletters, decisionhealth - 2009 Issue 3 (March)
Getting paid: CMS clarifies anti-markup provisions
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Article Overview
This article reviews CMS guidance on anti-markup provisions affecting diagnostic tests furnished in physician practice settings, with emphasis on diagnostic services such as EMG and nerve conduction studies. It is aimed at physicians, group practices, billing staff, and coding professionals who need a general understanding of when CMS applies payment-limit rules and how the agency describes practice-sharing scenarios. The article also summarizes CMS’s illustrative examples and the timing of the clarified guidance.
Why This Topic Matters
It helps practices understand CMS payment policy changes that can affect billing workflows, reimbursement, and compliance for diagnostic testing services.
Article Sections
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Anti-markup rule overview
Introduces CMS’s policy framework for diagnostic testing services and the broad circumstances that trigger the anti-markup provisions.
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What are the limits?
Summarizes the general payment-limit framework described by CMS and the situations in which the rule may apply.
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How CMS defines sharing a practice
Explains the general criteria CMS uses to determine when a performing physician is considered to be sharing a practice with the billing physician or supplier.
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CMS examples
Reviews illustrative scenarios CMS published to show different practice arrangements and testing locations.
What You Will Learn
- The general purpose of CMS anti-markup provisions for diagnostic testing services
- The broad circumstances that can trigger the anti-markup policy
- How CMS describes practice-sharing relationships for billing purposes
- The types of illustrative scenarios CMS uses to explain the policy
- Why the clarified guidance matters for practice operations and compliance
Who Should Read This
- Physicians
- Group practices
- Medical billing staff
- Coding professionals
- Compliance teams
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