tci Medicare Compliance & Reimbursement - 2010 Issue 18
Stark Compliance: Offering In-Office Advanced Imaging Services? Get Ready to Enlighten Your Patients About Ownership, Other Options
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Article Overview
This article explains a proposed CMS change related to Stark law and in-office ancillary imaging services, with emphasis on patient disclosure, ownership transparency, and implementation timing. It is aimed at physicians, practice managers, compliance staff, and healthcare attorneys who follow federal physician self-referral policy, imaging utilization, and Medicare regulatory updates. The discussion covers the proposed rule, questions about the scope of the disclosure mandate, recordkeeping considerations, and broader policy concerns affecting physician office-based imaging.
Why This Topic Matters
The proposal could affect how physician practices that offer advanced imaging in-office communicate ownership interests and available alternatives to patients. It also signals possible future changes in Stark-related imaging policy and compliance expectations.
Article Sections
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CMS proposed disclosure requirement and timing
Introduces the proposed federal reporting mandate and its planned effective date. Summarizes the regulatory context and the services discussed at a high level.
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Proposed Physician Fee Schedule Rule Addresses Key Issues
Reviews major unanswered questions addressed in the proposed rule. Focuses on the scope of the requirement, content of the notice, and related policy issues.
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Prepare Now for Jan. 1 Rollout
Discusses implementation planning, documentation practices, and state-law considerations. Also covers practitioner and legal perspectives on readiness for the change.
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Could Requirement Chill Utilization?
Explores views on whether the new disclosure could influence ordering or use patterns. Presents commentary about possible market and behavior effects.
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Larger Threat Could Be Looming
Addresses broader policy concerns beyond the proposed disclosure requirement. Discusses potential future changes to physician-office imaging policy and utilization oversight.
What You Will Learn
- The general purpose of the proposed Stark-related disclosure requirement
- How CMS framed the scope and implementation timing of the proposal
- What kinds of operational and documentation issues practices may need to consider
- How commentators viewed possible effects on imaging utilization and future policy changes
Who Should Read This
- Physicians
- Medical practice administrators
- Compliance professionals
- Healthcare attorneys
- Radiology and imaging practice managers
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