Among its many provisions, the newly signed Patient Protection and Affordable Care Act has imposed a new requirement on physicians who rely on the Stark "In-Office Ancillary Services" exception.  Physicians who refer patients for CT, MRI or PET (or other Stark services as designated by the Secretary of HHS) that will be provided by the referring physician’s practice

Under the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), all Medicare suppliers of the technical component of advanced imaging services have until by January 1, 2012 to become accredited by an accreditation organization designated by the Secretary of Health and Human Services . This includes physicians, non-physician practitioners, and physician and non-physician

Much has been in the news lately about the Children’s Health and Medicare Protection (CHAMP) Act of 2007 recently introduced by the House democrats.   The Bill’s proponents claim that if enacted it will provide insurance coverage for millions of children and improve and strengthen Medicare for America’s seniors and people with disabilities.  What Physicians — particularly surgeons

As lucrative ancillary services continue shift from hospitals to outpatient sites, hospitals are anxious to find ways to keep they’re hand in the mix.  Not surprisingly, physician-hospital joint ventures are all the rage.  While such ventures can be legally structured, the stakes of failing to comply with applicable legal requirements can be very high.  For important considerations

On February 19, 2007 (but effective retroactively to January 26, 2007), the Centers for Medicare and Medicaid Services (CMS) rescinded the controversial IDTF transmittal referrenced in the February 18, 2007 entry on this Blog.  A copy of the notice can be found here: Transmittal 187.  Those guidelines would have imposed major new conditions on independent diagnostic testing

A recent bill proposed by the Pennsylvania House of Representatives would, among other things, reinstate the Certificate of Need (CON) program in Pennsylvania.  Specifically, House Bill 305, introduced on February 7, 2007, would require anyone proposing to make capital expenditures in excess of $500,000 for replacement technology or $1,000,000 for equipment or improvements in

Building and/or investing in an ambulatory surgery center (ASC) is a great way to gain control over the surgical side of your practice and can also be an excellent source of ancillary revenue.  However, start-up costs can be prohibitive and building and running an ASC can be time consuming.  Not surprisingly, many physicians are tempted to "partner" with other investors as