Anti-markup Policy Changes Effect Physicians/Suppliers
The Centers for Medicare & Medicaid Services (CMS) is revising certain Medicare policy which may affect physicians and suppliers who submit claims for diagnostic tests to Medicare.
Revisions to Publication 100-04, Medicare Claims Processing Manual, chapter 1, sections 30.2.9 and 126.96.36.199 (as codified in 42 CFR § 414.50) include two alternative methods for determining when to apply the anti-markup payment limitation, and changes to certain terminology.
These policy revisions, which go into effect March 15, were provisions of the 2008 Physician Fee Schedule (PFS) final rule (72 FR 66222) but were not finalized until the 2009 PFS final rule (73 FR 69799).
CMS Transmittal 1892, Change Request (CR) 6733 and Medicare Learning Network (MLN) Matters article MM6733 provide instructions for determining when the anti-markup payment limitation may apply to a physician/supplier submitting claims for diagnostic tests (other than clinical diagnostic laboratory tests) to Medicare.
Note that CMS also is replacing all references to the terms “purchased diagnostic test” and “purchased test interpretation” with “anti-markup test” or “diagnostic tests subject to the anti-markup payment limitation.”