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Using our xray machine to do outside xrays

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I work for an orthopaedic group and we have a brand new x-ray machine. The PCP on the second floor of our building would like to refer his x-rays down to our office for my staff to take the x-ray, my physician to read the x-ray and dictate a report and then bill for the x-ray - even though they will never see or treat the patient themselves. Does anyone have any knowledge of how this would work or if it is even legal?
 

thomas7331

True Blue
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I believe this could be done legally, however I would strongly recommend having an attorney review any kind of referral arrangement prior to doing this because of the complexity of the anti-kickback statues. You would want to make sure there are no financial incentives or conflicts of interest present in the relationships between providers that would put the two practices at risk. I'd also recommend having the attorneys look at whether or not the regulations governing diagnostic radiology services allow for your orthopedic group to offer services essentially equivalent to what an independent diagnostic imaging facility - there may be additional requirements that must be met in order to offer this service to outside providers. Sorry if that's not much help, but these kinds of legal questions are a little outside the scope of most coders' training.
 
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