Medicare payment is contingent on appropriate supervision of diagnostic tests and proper use of radiologist assistants: is your practice meeting the current requirements?

The Medicare rules governing the supervision of diagnostic tests have changed over time, as have the skills and training of radiologist assistants, who may have the education and clinical skills to deliver surgical and invasive procedures often performed as part of a radiology practice. However, for the purposes of Medicare coverage, radiologist assistants are not yet recognized as independent providers or suppliers whose services are reimbursed separately from those of radiologists. As a result, services rendered by radiologist assistants are significantly limited by the Medicare physician supervision requirements and other Medicare billing rules. The authors describe the Medicare coverage and payment rules for working with radiologist assistants in hospital and nonhospital settings for both diagnostic testing and surgical or invasive procedures. The article also includes a summary of the current Medicare supervision requirements for a diagnostic test on the basis of the place of service: hospital, physician office, or independent diagnostic testing facility.

Reassignment reform: a possible regulatory tool to stunt the growth of in-office imaging.

The expansion of the Medicare reassignment rule in 2003 to permit independent contractors to perform professional services off-site has been cited as a factor potentially contributing to the marked increase in physician practices billing for diagnostic testing. In an effort to curb this growth, the Centers for Medicare and Medicaid Services is contemplating further revisions to the Medicare reassignment rules as described below that would effectively preclude ordering physicians from marking up not only the technical, but also the professional components of any services purchased or obtained under contract from radiology groups or other imaging service providers.