In-Office Ancillary Services Disclosures
Patient protection and disclosure are a key part of the Patient Protection and Affordable Care Act (PPACA). PPACA promotes ways to help patients take more control of their health care by providing more information to help them make decisions that work for them.
Just one of the many changes in the PPACA includes disclosure requirements for in-office ancillary services (IOAS). The current law prohibits physicians from referring patients for ancillary services in which they have a financial relationship.1 The current law has an exception that permits a physician in a solo or group practice to order and provide certain services in the office of the physician or group practice if specific criteria are met.
PPACA allows another exception related to physician referrals for MRI, CT, PET, and other designated health services. The intent of this exception is to help physicians make rapid diagnoses and begin treatment during a patient's office visit. Under PPACA, physicians can refer patients for these services if they have a financial relationship, provided the referral is accompanied by a written notice at the time of imaging service orders that states the patient may obtain services from other suppliers in the area. This written notice must also provide the patient with a list of the providers who can furnish these services2.
Beginning in January 2011, CMS is requiring that the disclosure statement be written as to be reasonably understood by all patients, and that the disclosure list contain suppliers only who are located within 25 miles of the service location at the time of the referral. 3
These changes may have an impact on your practice if you provide ancillary services like MRIs, CTs and PET scans. The impact on your practice and the amount of preparation can depend on the type and frequency you provide these services. Here are some things to consider:
Assess the Potential Impact on Your Practice:
Loss of revenue for in-office ancillary services to hospitals and other physicians
Reduction of overall imaging service market for Medicare patients as providers become more hesitant to provide in-office ancillary services
Things to Consider:
Discuss impact of referral process with local physician practices to help streamline availability of imaging services within your area
Investigate the payer mix of referring physicians to confirm acceptance of Medicare patients prior to referrals
Ways to Prepare:
Create draft disclosure statement for patients that meets CMS' guidelines
5 alternate suppliers within 25 miles of the physician’s office at the time of referral must be included on the disclosure form
- The name, address, and phone number of alternate suppliers
must be included
References:
1 "Financial Relationships Between Physicians and Entities Furnishing Designated Health Services" 69 Fed. Reg. 126 Section 411.350(a), March 26, 2004.
2 Heath System Reform Insight - August 12, 2010. American Medical Association. Accessed September 14, 2010. Available at:
http://www.ama-assn.org/ama/pub/health-system-reform/resources/insight/august-2010/12aug2010.shtml
3 42 CFR Parts 405, 409, 410 et al. Medicare Program; Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2011; Final Rule. November 29, 2010.
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