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 ...
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
- Page 165 and 166: CMS-1403-FC so the CY 2009 base com
- Page 167 and 168: CMS-1403-FC patient utilization gro
- Page 169 and 170: CMS-1403-FC make those estimates. A
- Page 171 and 172: CMS-1403-FC After removing the enro
- Page 173 and 174: CMS-1403-FC For CY 2009, we propose
- Page 175 and 176: CMS-1403-FC plain language over pol
- Page 177 and 178: CMS-1403-FC four quarters of ASP pr
- Page 179 and 180: CMS-1403-FC composite rates. The wa
- Page 181 and 182: CMS-1403-FC from the figure in the
- Page 183 and 184: CMS-1403-FC that our goal is the ev
- Page 185 and 186: CMS-1403-FC the average wage index
- Page 187 and 188: CMS-1403-FC Labor Statistics, to de
- Page 189 and 190: CMS-1403-FC been previously deemed
- Page 191 and 192: CMS-1403-FC CBSA where the campuses
- Page 193 and 194: CMS-1403-FC composite rates during
- Page 195 and 196: CMS-1403-FC target amount of compos
- Page 197 and 198: CMS-1403-FC admission. That is, the
- Page 199 and 200: CMS-1403-FC that CMS consider issue
- Page 201 and 202: CMS-1403-FC hold the provider in wh
- Page 203 and 204: CMS-1403-FC Comment: Commenters rai
- Page 205 and 206: CMS-1403-FC who have enrolled in th
- Page 207 and 208: CMS-1403-FC ● Posting IDTF standa
- Page 209 and 210: CMS-1403-FC other diagnostic testin
- Page 211 and 212: CMS-1403-FC entities furnishing mob
- Page 213 and 214: CMS-1403-FC state Radioactive Mater
- Page 215: CMS-1403-FC equipment and provide t
- Page 219 and 220: CMS-1403-FC believe that requiring
- Page 221 and 222: CMS-1403-FC these claims will ensur
- Page 223 and 224: CMS-1403-FC and NPP organizations,
- Page 225 and 226: CMS-1403-FC prior to their enrollin
- Page 227 and 228: CMS-1403-FC The date of approval is
- Page 229 and 230: CMS-1403-FC organizations, and indi
- Page 231 and 232: CMS-1403-FC To assist physician and
- Page 233 and 234: CMS-1403-FC Comment: Several commen
- Page 235 and 236: CMS-1403-FC date of filing and circ
- Page 237 and 238: CMS-1403-FC services are complying
- Page 239 and 240: CMS-1403-FC days when a Presidentia
- Page 241 and 242: CMS-1403-FC effective date under ap
- Page 243 and 244: CMS-1403-FC Comment: The suggestion
- Page 245 and 246: CMS-1403-FC Response: We thank the
- Page 247 and 248: CMS-1403-FC provider enrollment giv
- Page 249 and 250: CMS-1403-FC instead, it will force
- Page 251 and 252: CMS-1403-FC Response: As stated abo
- Page 253 and 254: CMS-1403-FC Comment: One commenter
- Page 255 and 256: CMS-1403-FC In an attempt to ensure
- Page 257 and 258: CMS-1403-FC rule, rather than limit
- Page 259 and 260: CMS-1403-FC changes have occurred,
- Page 261 and 262: CMS-1403-FC Response: While we moni
- Page 263 and 264: CMS-1403-FC records faster and more
- Page 265 and 266: CMS-1403-FC In §424.521(a)(1), we
<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