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CMS-1403-FC
commenters are distinctions that treat groups differently
from solo practitioners and that discriminate between
different types of groups. The commenter gave the example
of a solo practitioner with five offices with an x-ray
machine in each: provided that he or she regularly
practiced in each office, he could order diagnostic tests
at all five locations, or from any one of them, and the
tests would be treated as “furnished” inside the practice
rather than “purchased.” According to the commenter, a
group practice, on the other hand, that has primary care
physicians in one building and specialists in another
either has to have x-ray machines in both buildings, to be
used only by the physicians in each building, or do
diagnostic testing in only one building and treat the group
practice members in the other building as “purchasing” the
tests. The commenter also described its understanding of
the proposed rule, stating that, when diagnostic tests are
provided in a centralized building by a non-profit multi-
specialty group, they would be considered “furnished,” but
the same tests provided by a physician-owned group that is
otherwise comparable in size and scope would be considered
“purchased.” The commenter questioned the relevance of
these distinctions related to quality, convenience,
efficiency, utilization, or potential abuse.
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