Stark Compliance:
Offering In-Office Advanced Imaging Services? Get Ready to Enlighten Your Patients About Ownership, Other Options
Published on Tue Aug 24, 2010
Find out what CMS has proposed and what this new Stark reporting mandate could portend. Picture this: A Medicare patient goes to see a physician who orders a medically necessary MRI or CT scan. The patient receives the service in the physician practice's imaging center housed in the same office suite. Watch out: That commonplace self-referral may soon no longer comply with the Stark in-office ancillary services exception -- not if the physician fails to inform the patient in advance about his financial interest in the imaging service. The written disclosure also has to let the patient know that she can get the imaging service(s) from other nearby suppliers. What and when: The Affordable Care Act (ACA) implements the self-disclosure requirement for MRI, CT, PET scans, and "any other designated health services that the Secretary of HHS determines appropriate." The ACA specified Jan. 1, 2010 or after as the implementation [...]