Radiology Coding Alert

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:

1. 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.
   
2. 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.
   
3. 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.