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

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

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19.02.2013 Views

CMS-1403-FC Comment: Several commenters requested that we not require mobile units that furnish diagnostic testing services to enroll in Medicare or be required to bill for all of the services they furnish. Response: We disagree with the commenters. In order to maintain program integrity and enable CMS to monitor services furnished by mobile units providing diagnostic testing services, we maintain that a mobile entity providing diagnostic testing services must enroll for diagnostic imaging services that it furnishes to a Medicare beneficiary, regardless of whether the service is furnished in a mobile or fixed base location. We are requiring these mobile IDTFs to bill for the services that they furnish unless they are billing under arrangement with hospitals. Comment: One commenter stated the contractual arrangement between mobile diagnostic imaging services companies and hospitals are commonplace throughout the United States health care industry and these long-standing arrangements, which can be short-term or long-term depending upon hospital demand, service a variety of important needs within the hospital and provider community, including a valuable means to address capacity, volume and equipment cost issue and limitations imposed by State Certificate of Need (CON) requirements. 216

CMS-1403-FC Response: We understand the commenters’ concerns and we are requiring these mobile IDTFs to bill for the services that they furnish unless they are billing under arrangement with hospitals. Comment: One commenter suggested that we should provide clear and concise guidance on billing protocols that permit hospitals to continue billing for mobile diagnostic testing services furnished as inpatient and outpatient hospital services and allow informational billing (that is, no payment impact) by the mobile entities through the use of a billing modifier. Response: We believe these comments are outside the scope of the rule. Comment: One commenter does not support a restriction of an enrolled provider/supplier that would preclude them from arrangements that are allowed under the purchased diagnostic test or purchased interpretation rules due to their method of connecting a patient with testing equipment. Response: We understand the commenters’ concerns and we are requiring these mobile IDTFs to bill for the services they furnish unless they are billing under arrangement with hospitals. 217

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

Response: We understand the commenters’ concerns and<br />

we are requiring these mobile IDTFs to bill for the<br />

services that they furnish unless they are billing under<br />

arrangement with hospitals.<br />

Comment: One commenter suggested that we should<br />

provide clear and concise guidance on billing protocols<br />

that permit hospitals to continue billing for mobile<br />

diagnostic testing services furnished as inpatient and<br />

outpatient hospital services and allow informational<br />

billing (that is, no payment impact) by the mobile entities<br />

through the use of a billing modifier.<br />

Response: We believe these comments are outside the<br />

scope of the rule.<br />

Comment: One commenter does not support a restriction<br />

of an enrolled provider/supplier that would preclude them<br />

from arrangements that are allowed under the purc<strong>has</strong>ed<br />

diagnostic test or purc<strong>has</strong>ed interpretation rules due to<br />

their method of connecting a patient with testing<br />

equipment.<br />

Response: We understand the commenters’ concerns and<br />

we are requiring these mobile IDTFs to bill for the<br />

services they furnish unless they are billing under<br />

arrangement with hospitals.<br />

217

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