New Imaging Disclosure Requirements Began January 1, 2011

Beginning January 1, 2011, a patient who is referred for MRI, CT or PET scans by a physician to a facility that he or she has an ownership interest in, must also be provided with a list of alternative options to receive their imaging services. Physicians are required to begin to distribute a list of at least five alternative suppliers (except where fewer than five exist), which can include hospitals, within a 25 mile radius of the referring office. This distribution must be done every time a referral takes place. Although there is no requirement to include the list within the medical file, it is suggested that documentation be made to note the disclosure was provided to the patient.

Most diagnostic imaging centers and radiology groups won’t be directly impacted. However, there is no better time than now to make sure your practice is on the list of alternative imaging providers or to make sure your practice is in accordance with the new imaging disclosure requirements.

CMS’ final rules were published on November 29, 2010, and can be found at 75 Fed. Reg. at 73586-7, 73616 if there are any further questions.

ADVOCATE will continue to provide updates on this matter as they arise.

With best regards,
Kirk Reinitz, CPA