Dorsey attorneys Ross C. D'Emanuele, Urika Vettleson and Stephanie Friedland analyzed in HealthLaw 360 the final round of rule making in 2008 by the Centers for Medicare and Medicaid Services (CMS). They profile physician payment rate amendments and proposed revisions to the federal physician self-referral (or Stark) regulations, as well as sweeping provisions involving diagnostic testing and anti-markup rules.
D'Emanuele et. al. suggest that the anti-markup rule in particular will have a drastic impact on physician groups who perform in-office diagnostic testing. Groups that structured their imaging to comply with the centralized building component of the Stark in-office ancillary services exception may find that the new rules have turned a profitable part of their practice into a net loss.
Read the complete HealthLaw 360 analysis (PDF link)
"CMS: Draconian Rulemaking For Physicians, Testing" was published by HealthLaw 360. Republished under rights reserved to the authors.