Stark Healthcare Rules and Exceptions for Radiology

Stark law impacts specifically the diagnostic radiology arrangements. Some of the most recent changes and development have really focused specifically on radiology and diagnostic imaging. Go through this healthcare compliance article to know more.

In looking at where we are today, we have an administration that's very much focused on the recovery and providing incentives and stimulus for healthcare and also to promote healthcare requirements. So maybe these issues of Stark and so forth are kind of by the wayside. You might expect that there is going to be a ramp up enforcement as we move really from a rule making situation now to an enforcement or compliance situation with respect to these laws.

This has been a multiple year whether the 20 year or so process to get this law - especially with Stark law, to where it is today with a lot of healthcare rules and a lot of rulemaking and so forth. And the government also sees it as an opportunity for possible cost savings, utilization approach to really start to try to enforce the Stark law and what we call related laws including the anti-markup rule.

You might be seeing remnants of interests in dealing specifically with arrangement that have been in the past between imaging centers are also called independent diagnostic testing facilities or IDTFs and doctors and doctor groups involving what we might call a wholesale/retail type of arrangement. Some of these new healthcare rules really are directed towards ending those types of relationships or modifying them.

And we're also seeing even at the state level efforts to try to moderate that kind of arrangement both from a Stark law perspective and to just go after those types of arrangements.

Healthcare Training Tip: Remember that there's attributes of radiology that you may or may not find in other types of ancillary services that make it kind of unique and kind of specific with respect to figuring out what you got to do under these laws.

And particularly it's understanding what service is being provided, the setting of that service - that is the location of it which becomes really critical, and the source of the referral and really the referral recipient as well, understanding who the referral recipient is to ensure healthcare compliance.

We also know that radiology, these kinds of tests and so forth include two components usually. And sometimes they're built separately. Sometimes they're built globally, technical component, the test itself and PC, the professional component or the interpretation by a physician or by a radiologist.

Our expert suggested in a health system conference that keeping all that in mind in really important because sometimes we're really talking about just the test. Sometimes we're talking about the whole enchilada. The setting is important, both of the referral source and the referral recipient particularly of where the test is occurring and where the interpretation is occurring.

And that might be a hospital. It might be an office. It might be an independent center or as we talked about, IDTF. It might actually be a center that's  conducting teleradiology because that is often now done a lot especially in terms of the interpretation component, the PC.

And then the person who's referring in terms of their relationship with the recipient becomes important. Are they the radiologist who's going to do the interpretation him or herself? It's not usually the case. It's usually the patient's attending physician who will order these tests and who may have some kind of financial relationship with the recipient, that is the center or the hospital or the medical group.

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