Imaging: CMS Grants Anti-Markup Provision Reprieve 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 explains CMS’s postponement of key Medicare anti-markup provisions and why the delay matters for imaging practices and certain pathology services. It focuses on the scope of the deferred implementation, the exceptions that were not delayed, and the remaining uncertainty around purchased diagnostic services, centralized settings, and outside technical staffing arrangements. The piece is aimed at practices, compliance staff, coders, and healthcare attorneys following Medicare payment policy and service arrangement issues.

Why This Topic Matters

The article helps readers understand which parts of the anti-markup policy were deferred and which operational questions remain unresolved for practices that furnish diagnostic services under Medicare.

Article Sections

  1. Delay of the anti-markup provisions

    Summarizes CMS’s postponement of the new Medicare anti-markup rule and the general impact on provider billing arrangements.

  2. Exceptions that were not delayed

    Describes the categories of diagnostic services that remain subject to the policy timeline and the areas of continuing attention for practices.

  3. Remaining uncertainty for purchased diagnostic services and staffing arrangements

    Discusses unresolved questions about outsourced technical services, performance of services, and related Medicare enrollment and reassignment concerns.

What You Will Learn

  • How CMS’s delay affects the implementation timeline for Medicare anti-markup provisions
  • Which broad types of diagnostic services were not included in the postponement
  • What operational and compliance questions remain for practices using outside personnel or centralized service arrangements
  • Why imaging and pathology groups should pay attention to payment policy timing and service-location issues

Who Should Read This

  • Medical coders
  • Compliance professionals
  • Practice managers
  • Healthcare attorneys
  • Radiology and pathology practices

Codes Discussed

  • CPT: 88304
  • CPT: 88305

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