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<strong>CMS</strong>-1403-FC<br />

entities furnishing mobile diagnostic services enroll in<br />

Medicare and bill directly for the mobile diagnostic<br />

services that they furnish, regardless of where the<br />

services are furnished. We believe that entities<br />

furnishing mobile diagnostic services to Medicare<br />

beneficiaries must be enrolled in the Medicare program,<br />

comply with the IDTF performance standards, and directly<br />

bill Medicare for the services they furnish.<br />

While we understand that a mobile entity can furnish<br />

diagnostic testing services in various types of locations,<br />

we stated that we believe that it is essential that mobile<br />

entities use qualified physicians or nonphysician personnel<br />

to furnish diagnostic testing procedures and that the<br />

enrolled mobile supplier bill for the services furnished.<br />

We maintain that it is essential to our program integrity<br />

and quality improvement efforts that an entity furnishing<br />

mobile diagnostic testing services complies with the<br />

performance standards for IDTFs and bill the Medicare<br />

program directly for the services furnished to Medicare<br />

beneficiaries.<br />

Since we believe that most mobile entities are already<br />

billing for the services they furnish, whether the service<br />

was provided in a fixed-based location or in a mobile<br />

facility, we proposed that this provision would be<br />

211

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