·         IDTFs may not share space or equipment with another active Medicare supplier. (Note: Physicians owning an IDTF and sharing space are exempt from this requirement.)   Reportedly, CMS has informally interpreted "supplier" broadly to include physicians, which may jeopardize many common leasing arrangements between ITDFs and physician practices.

·         Non-physician personnel that work at the IDTF that require certification or a license (e.g. technicians) must be full-time W-2 employees of the IDTF itself, not subcontractors.  It is unclear whether CMS will approve any common-paymaster or employee leasing arrangements.

·         IDTFs may not be reimbursed for any services provided to Medicare beneficiaries prior to the date the carrier approves the IDTF application.  New physicians must be added to the ITDF’s account and processed before the IDTF can be paid for interpretations performed by such new physicians.  These payment delays are likely to result in cashflow problems for IDTFs.