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CMS-1403-FC
were concerned that this approach focuses only on where the
test is performed and not by whom. Some commenters did not
support our proposal to clarify “office of the billing
physician or other supplier” as including diagnostic
testing performed in the “same building,” but not in a
“centralized building,” preferring that “office of the
billing physician or other supplier” also encompass
diagnostic testing performed in a “centralized building.”
Most commenters agreed with our proposed clarification
that the TC of a diagnostic test is not “purchased from an
outside supplier” if the TC is both conducted by the
technician and supervised by the physician within the
office of the billing physician or other supplier. We
received a few comments, some in favor of and some opposed
to, the proposed exception for diagnostic tests ordered by
physicians in a physician organization with no owners who
have the right to receive profit distributions. Most of
the comments that we received in response to the “net
charge” solicitation expressed dissatisfaction regarding
the disallowance of overhead costs in the calculation of
the “net charge.” Other commenters, however, agreed that
these costs should not be included and that only those
charges that are incurred from paying the physician
providing the PC or supervising the TC should be included.
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