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Thread: New Requirement for Phy "In-Off Ancillary Srvc"

  1. #1

    Question New Requirement for Phy "In-Off Ancillary Srvc"

    AAPC: Back to School
    Good morning fellow coders. I have received the email below but have been unable to locate any guidence online to confirm it. Has anyone heard about this requirement and/or can you tell me where to go online to find more info? Thank you for your time and consideration.
    Lila L Taylor, CPC, COBGC

    > New Disclosure Requirement Immediately Required for Physicians for “In-Office Ancillary Services”
    > Most of the provisions of the newly adopted Patient Protection and Affordable Care Act (the “Act”) are effective in the future. But, a key provision is immediately effective and changes the way physicians must practice.
    > The Act places an immediate burden on physicians to make disclosures and provide alternatives to patients when the physician’s office provides patients with X-rays, Pet scans and MRIs, and certain other ancillary services reimbursed by Medicare or Medicaid. These provisions are mandatory and failure to comply means that Medicare or Medicaid can’t be billed for the services.
    > A little-noticed provision of the Act amended Stark Law’s In-Office Ancillary Services Exception (the “IOAS”) to require disclosure of alternative providers of certain services. The IOAS is perhaps the most utilized exception to the Stark Law, allowing a physician to refer patients for designated health services (“DHS”) in which the physician has a financial interest, so long as certain requirements are met. Under existing law, those requirements have been:
    > (1) the DHS must be personally furnished by or under the direct supervision of the referring physician or another physician in the same group practice,
    > (2) in the same building in which the referring physician performs non-DHS services or in a centralized building used by the group practice for provision of DHS (so long as additional requirements are met), and
    > (3) the DHS must be billed for by the referring physician, the group practice, or by an entity wholly-owned by the group practice.
    > The IOAS has now been amended to add a new requirement that the referring physician, when ordering a CT, MRI, or PET scan, in addition to any other DHS that the Secretary of HHS deems appropriate, must provide the patient with a list of other providers in the area that can provide the same service. The area requirement is based on the area where the patient resides, rather than where the group practice is located, which will only add to the burden on physicians to comply with this new requirement.
    > While the provision has an effective date of January 1, 2010, compliance would be impractical until some period of time after the Act was signed into law on March 23, 2010. There is no requirement that regulations or other guidance be issued before the provision becomes effective. That means that this provision, and the requirement to provide the list of alternative providers, is now in-force and providers should begin taking steps to comply as soon as possible.

  2. #2


    I was unable to Google items for this specific topic (i.e. http://www.opencongress.org/bill/111-h3590/show); probably the reason for such opposition of the 2000+ page bill.

  3. #3
    Join Date
    Apr 2007
    Greeley, Colorado

    Default Who sent the email?

    Lila - who sent the email? This could be huge...
    Lisa Bledsoe, CPC, CPMA

  4. #4


    Lisa- the email came from an employee of Zetter Healthcare Management Consultants

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