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CMS-1403-FC
with Group Practice C to render services in place of
Physician B, who is on vacation. Physician B performs 100
percent of her professional services through Group Practice
C. This arrangement meets the requirements of Alternative
1, because Physician B performs at least 75 percent of her
professional services through Group Practice C. It is
irrelevant whether, or the extent to which, Physician A
furnishes professional services for Group Practice C
outside the locum tenens arrangements, for purposes of
determining whether the anti-markup payment limitation
applies to the services provided by Physician A under the
locum tenens arrangement.
Comment: Many commenters were opposed to the proposed
Alternative 1 approach to determining whether a physician
shares a practice with the billing physician or other
supplier. Some commenters stated that they employ a
pathologist in-house in order to improve quality of care
by: (1) using specialized pathologists for digestive
diseases; (2) forming normative standards based on the
practices of the physicians in the practice; and (3)
decreasing the turnaround time for diagnostic tests. Other
commenters, who are physicians, stated that they were
unhappy with the professional services provided by
commercial laboratory companies due to slow turnaround time
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