Medicare 2009 Physician Fee Schedule Due Soon
The Final Rule for 2009 for the Medicare Physician Fee Schedule is expected by November 1, 2008. Medicare has not always published the Final Rule before the annual November 1 target date. The Proposed Rule (published July 7) contained several provisions that would impact many physician practices should they be included in the Final Rule. Specifically, CMS has proposed that any physician office providing diagnostic imaging (including basic X-ray) would need to enroll as an Independent Diagnostic Testing Facility (IDTF). This would place additional burden and costs on practices subject to the IDTF regulations.
CMS was also considering
delaying this (if included) to sometime after January 1, 2009, but did not
specify whether they would or not. The Proposed Rule also addressed
"Physician Self-Referral and Anti-Markup" issues that included clarification
of the anti-markup rules that were initially in the 2008 Final Rule but were
almost immediately suspended due to unforeseen implications by CMS. The
Proposed Rule was not definitive in how CMS might ultimately address this
issue but proposed, in some cases, two alternative approaches they were
considering. These regulations would affect practices that have multiple
offices or "time share" diagnostic imaging facilities.
Look for the Final Rule to be published soon. We are awaiting the Final Rule
so that we may assist practices as necessary in complying with the new
regulations. Please
contact us if you would
like to discuss this topic further.
Health Care Commentaries is
provided by Somerset’s
Health Care Team
for our clients and other interested persons upon request. Since
technical information is presented in generalized fashion, no final
conclusion on these topics should be made without further review. For
additional information on the issues discussed, please contact a member
of our Health Care Team. This
document is not intended or written to be used, and cannot be used, for
the purpose of avoiding tax penalties that may be imposed on the
taxpayer.
Somerset CPAs,
P.C.
3925 River Crossing Parkway, Third Floor
Indianapolis, Indiana 46240
317.472.2200 • 800.469.7206 • FAX 317.208.1200
http://healthcare.somersetcpas.com
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