Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
state Radioactive Materials licenses, it does not subject
the mobile provider to the same pre-opening inspections
that the fixed sites are subject to. Second, some mobile
providers are able to secure accreditation from certain
accrediting agencies that furnish a global, or “hub”,
accreditation certification.
Response: We thank the commenter for its support.
Comment: One commenter stated that our proposal to
require mobile providers to enroll in Medicare as IDTFs, be
subject to all IDTF performance standards, and to bill
Medicare directly, not only would it create a single,
universal standard for quality among all imaging providers,
but would also level the playing field in the competitive
market for management services for companies which provide
high quality fixed site programs for Medicare-enrolled
physician practices and their Medicare enrollees.
Response: We appreciate the comments and thank the
commenter for their support.
Comment: One commenter supports the proposal
requiring these entities to enroll in Medicare and as such,
for them to be required to abide by applicable Medicare
policies. The commenter continued to state that they do
not oppose the direct billing requirement but that if the
proposal is finalized, CMS needs to provide a great amount
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