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

Comment: Several commenters requested that we not<br />

require mobile units that furnish diagnostic testing<br />

services to enroll in Medicare or be required to bill for<br />

all of the services they furnish.<br />

Response: We disagree with the commenters. In order<br />

to maintain program integrity and enable <strong>CMS</strong> to monitor<br />

services furnished by mobile units providing diagnostic<br />

testing services, we maintain that a mobile entity<br />

providing diagnostic testing services must enroll for<br />

diagnostic imaging services that it furnishes to a Medicare<br />

beneficiary, regardless of whether the service is furnished<br />

in a mobile or fixed base location. We are requiring these<br />

mobile IDTFs to bill for the services that they furnish<br />

unless they are billing under arrangement with hospitals.<br />

Comment: One commenter stated the contractual<br />

arrangement between mobile diagnostic imaging services<br />

companies and hospitals are commonplace throughout the<br />

United States health care industry and these long-standing<br />

arrangements, which can be short-term or long-term<br />

depending upon hospital demand, service a variety of<br />

important needs within the hospital and provider community,<br />

including a valuable means to address capacity, volume and<br />

equipment cost issue and limitations imposed by State<br />

Certificate of Need (CON) requirements.<br />

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