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CMS-1403-FC
providers, the services provided, and associated charges as
separate line items on a single Medicare claim form. The
commenters further asserted that we would be able to
reconcile TC and PC components without an increase in
billing expenses to either the providers or Medicare. One
commenter expressed its view that the most straightforward
way to address potential overutilization caused by
physicians being able to profit by billing for diagnostic
services performed by others would be to implement a direct
billing requirement. The commenter suggested that this
would be a simple, understandable, bright-line rule that
could be effectively implemented and monitored. Another
commenter supported the establishment of direct billing for
anatomic and clinical pathology services for all payers,
public and private, so that payment should be made only to
the person or entity that performed or supervised the
service, except for referrals between laboratories
independent of a physician’s office. According to this
commenter, this policy would be consistent with ethics
principles that discourage fee-splitting.
Response: We appreciate the comments on whether, in
addition to or in lieu of the anti-markup provision, we
should prohibit reassignment in certain situations and
require the physician supervising the TC or performing the
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