End-of-Year Reminder to Physician Practices: Patient Notice Required Starting January 1 for Certain In-Office Ancillary Services Referrals

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Commencing January 1, 2011, physicians who refer Medicare patients to their practices for certain MRI, CT or PET services will be required to give their Medicare patients written notice of alternative suppliers. This is a new disclosure requirement created by Section 6003 of the Patient Protection and Affordable Care Act which amends the Stark Law’s In-Office Ancillary Services Exception. Physicians who rely on this Stark Law exception for referrals of MRI, CT or PET services to their practices after January 1, 2011 will be in violation of the Stark Law if they fail to comply with this new disclosure requirement.

CMS finalized the implementing regulations of the new disclosure requirement in the 2011 Physician Fee Schedule Final Rule (Final Rule), published in the November 29, 2010, Federal Register. In the Final Rule, CMS sets forth the following elements of the new disclosure requirement...

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Published In: Consumer Protection Updates, Health Updates, Insurance Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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