IMAGING: CMS Delays Imaging Anti-Markup Provision Until 2009

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

Article Overview

This article covers a CMS delay in the implementation of Medicare’s imaging anti-markup provisions and highlights the parts of the policy that were not delayed. It is relevant to imaging, pathology, and physician practice billing professionals who need to understand the timing, scope, and unresolved questions around the rule. The discussion focuses on general compliance issues, affected service categories, and commentary from legal experts.

Why This Topic Matters

The article matters because it addresses a Medicare payment-policy change that affects how physician practices structure and bill for imaging and certain pathology services. It also flags unresolved interpretive issues that may affect compliance planning.

Article Sections

  1. Delay in anti-markup implementation

    Summarizes the CMS postponement of the anti-markup provisions and the general timeframe involved. It frames the policy change in the context of Medicare billing for imaging-related services.

  2. Services not covered by the delay

    Describes the categories of services that were not included in the postponement and the related uncertainty for practices. The section focuses on the broad scope of the remaining policy questions.

  3. Questions about independent contractor technicians

    Discusses unresolved issues involving services furnished by outside technicians in group practice settings. It addresses the broader compliance concerns raised by different arrangements for furnishing diagnostic services.

  4. Whether the service is performed by the group or an outside supplier

    Explores the interpretive issue of how a diagnostic service arrangement may be characterized for billing purposes. The discussion stays at a general level about operational and payment implications.

What You Will Learn

  • How CMS delayed implementation of a Medicare imaging policy change
  • Which broad service categories were not included in the delay
  • What types of unresolved billing and compliance questions remained for physician practices
  • Why service arrangements involving outside technicians drew attention under the policy

Who Should Read This

  • Physician billing staff
  • Coding professionals
  • Practice managers
  • Health care attorneys
  • Imaging and pathology service administrators

Codes Discussed


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