CMS Pub. 100-04, ch. 35, § 10.2

A. Billing Issues

Nothing in this document or in the Medicare Enrollment Application, (CMS-855B) or the

Internet-based Provider Enrollment, Chain and Ownership System shall be construed or

interpreted to authorize billing by an IDTF, physician, physician group practice, or any

other entity that would otherwise violate the physician self-referral prohibition set forth in

§1877 of the Social Security Act and related regulations. A/B MACs (Part B) must deny

claims submitted in violation of §1877 and demand refunds of any payments that have

been made in violation of §1877.

Consistent with 42 CFR 410.32(a), the supervisory physician for the IDTF, whether or

not for a mobile unit, may not order tests to be performed by the IDTF, unless the

supervisory physician is the patient’s treating physician and is not otherwise prohibited

from referring to the IDTF. The supervisory physician is the patient’s treating physician

if he or she furnishes a consultation or treats the patient for a specific medical problem

and uses the test results in the management of the patient’s medical problem.

If an IDTF wants to bill for an interpretation performed by a physician who does not

share a practice with the IDTF, the IDTF must meet certain conditions concerning the

anti-markup payment limitation. If a physician working for an IDTF (or a party related to

the IDTF through common ownership or control as described in 42 CFR §413.17) does

not order the technical component or professional component of a diagnostic test

(excluding clinical diagnostic laboratory tests), it would not be subject to the anti-markup

payment limitation. (See Pub. 100-04, chapter 1, §30.2.9)

B. Transtelephonic and Electronic Monitoring Services

Transtelephonic and electronic monitoring services (e.g., 24 hour ambulatory EKG

monitoring, pacemaker monitoring and cardiac event detection) may perform some of

their services without actually seeing the patient. Most but not all of these billing codes

are 93012 ,93014, 93040, 93224, 93225, 93226, 93232, 93230, 93231, 93233, 93236,

93270, 93271, 93731, 93733, 93736, 95953, 95956, These monitoring service entities

should be classified as IDTFs and must meet all IDTF requirements. We currently do not

have specific certification standards for their technicians; technician credentialing

requirements for them are at A/B MAC (Part B) discretion. They do require a

supervisory physician who performs General Supervision. Final enrollment of a

transtelephonic or electronic monitoring service as an IDTF requires a site visit.

For any entity that lists and will bill codes 93012, 93014, 93268, 93270, 93271, 93272,

the A/B MAC (Part B) must make a written determination that the entity actually has a

person available on a 24 hour basis to answer telephone inquiries. Use of an answering

service in lieu of the actual person is not acceptable. The person performing the attended

monitoring should be listed in Section 3 of Attachment 2 of Form CMS-855B. The

qualifications of the person are at the A/B MAC (Part B)’s discretion. The A/B MAC

(Part B) shall check that the person is available by attempting to contact the applicant

during non-standard business hours. In Particular, at least one of the contact calls should

be made between midnight and 6:00 AM. If the applicant does not meet the availability

standard they should receive a denial.

C. Slide Preparation Facilities and Radiation Therapy Centers

Slide Preparation Facilities and Radiation Therapy Centers are not IDTFs. Slide

preparation facilities are entities that provide slide preparation services and other kinds of

services that are payable through the technical component of the surgical pathology

service. These entities do not provide the professional component of surgical pathology

services or other kinds of laboratory tests. The services that they provide are recognized

by A/B MACs (Part B) for payment, as codes in the surgical pathology code range

(88300) to (88399) with a technical component value under the physician fee schedule.

The services provided by these entities are usually ordered by and reviewed by a

dermatologist. Slide preparation facilities generally only have one or two people

performing this service.

All enrolled Slide Preparation Facilities must enroll separately with their Medicare

contractor. Radiation therapy centers provide therapeutic services and therefore are not

IDTFs. Radiation therapy centers must enroll separately with their Medicare contractor.