Radiology Coding Alert

You may pick up a $15,000 fine if you don't meet 1 of 3 exceptions The federal government is keeping a closer eye on nuclear medicine providers as of Jan. 1. Diagnostic and therapeutic nuclear medicine are now "designated health services" (DHS) under the Stark Law, which means you can't submit a Medicare claim (or bill anyone) for services if the referring physician has a financial relationship with your practice. Cost: Fines can reach $15,000 for each prohibited service, and you could be excluded from Medicare and Medicaid participation. Exceptions: According to a client bulletin by Edward Kornreich and Roger Cohen with New York-based Proskauer Rose, the only way out is to meet one of these safe harbors: The in-office exception: Group practices can self-refer Medicare patients for DHS services that take place in the same building as your office or in a space that your practice uses exclusively for at least six months out of the year.
The rural exemption: If your office furnishes at least 75 percent of its DHS services to patients who live in a rural area, you're home-free.
The "bona-fide employment relationships" and "personal services arrangement" exceptions: Your practice can receive nuclear-medicine referrals from a physician who works for it, as long as the physician has a fair contract that pays a reasonable rate for identifiable services and doesn't vary based on how many referrals the doctor sends you. If you missed the deadline: Get your house in order now and refund any improper payments, attorneys say.