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Self-referral of imaging and increased utilization: some practical perspectives on tackling the dilemma
1Arent Fox LLP, 1050 Connecticut Avenue, NW, Washington, DC 20036, USA. romano.donald@arentfox.com
Abstract:
Health care costs are higher in the United States than in any other country in the world, and imaging services have been growing much more rapidly than other services. Studies have shown a tendency for increased utilization of services, including imaging services, when referring physicians have ownership interest in the services. In recent years, the CMS has taken some action with respect to how it pays for imaging, including reducing physician payments when multiple images are taken on contiguous body parts during the same visit, establishing a cap on payments for certain imaging services, and imposing an antimarkup rule on diagnostic tests. In addition, CMS has made some changes to the Stark rules, which included adding nuclear medicine to the list of designated health services, prohibiting certain per-service or per-click leasing arrangements, and prohibiting physicians from owning entities that sell services to providers that then bill for them under arrangements. Because it is unclear whether these policy changes will have much effect on imaging utilization, CMS will continue to seek new ways to rein in utilization. In the near future, CMS and the US Department of Health and Human Services are likely to attempt to curb utilization not only through postpayment review and education but also through its various initiatives on improving the quality of services furnished to Medicare benificiaries.
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