Client Alert

New Medicare Enrollment and Certification Rules for Independent Diagnostic Treatment Centers: Are Prohibitions on Certain Equipment, Space and Employee Leasing Arrangements Around the Corner?

February 26, 2007

James F. Owens and Paul A. Gomez

By now, many healthcare providers and suppliers, and certainly those who are independent diagnostic treatment facilities, are at least generally aware of new rules for IDTF enrollment in and certification by the Medicare program. The final version of these new rules was published on December 1, 2006 and became effective January 1, 2007. What healthcare providers and suppliers may not be aware of is that, after publication of these new rules, CMS, in its Program Integrity Manual, published significant additional requirements on January 26, 2007 applicable to IDTFs that did not appear to be addressed expressly by the final rule. These new requirements were set to take effect on February 26, 2007, and had the potential to significantly impact the manner in which many IDTFs operate.

Thankfully for healthcare suppliers and providers, CMS announced a last-minute rescission of these new Manual requirements. Nevertheless, because the rescinded requirements may provide a window into CMS thinking on the subject and may be a precursor of additional regulations to come, it is useful to briefly examine some of the more substantive aspects of the rescinded requirements.

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