Changes in Medicare Payment, Billing and Enrollment Policies in the Final 2009 Medicare Physician Fee Schedule


Significant policy changes for physicians, nonphysician practitioners and other suppliers are contained in the 2009 Medicare Physician Fee Schedule final rule ("Final Rule"), which was displayed on October 30, 2008 and will be published in the Federal Register on November 19, 2008. This rule contains the final anti-markup provisions for diagnostic tests and new provider enrollment provisions. It also declines to extend the IDTF requirements to physicians and non-physician practitioners performing diagnostic tests in their offices, and makes many other policy pronouncements. The Final Rule was issued by CMS

as a final rule with comments, and CMS has solicited comments on specific sections of the rule. In this article, we summarize some of the issues addressed by the Final Rule, including Anti-Mark Up Rules; Incentive Payment and Shared Savings Programs; New DHS - Speech-Language Pathology; Independent Enrollment of Speech-Language Pathologists; Independent Diagnostic Testing Facilities (IDTFs); Mobile Entity Billing Requirements; Physician and NPP Enrollment Issues; and DME CPAP Standards.

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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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