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CMS Expected to Revise Condo Lab & TC/PC Rules

CEO SUMMARY: Expectations are that the Centers for Medicare & Medicaid Services (CMS) will take further action to rein in anatomic pathology arrangements used by physicians to capture revenue from their patient referrals. This may happen as soon as next month, when CMS publishes the 2…

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PhyTest Assists Doctors With Lab Testing Revenue

CEO SUMMARY: PhyTest, Inc., created a unique business model upon its founding in 1998. It primarily specializes in handling laboratory test billing and collection services to office-based physicians. It also provides evaluation, consulting, and implementation services to help physicians i…

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CMS Spotlights AP as It Delays Anti-Markup Rule

CEO SUMMARY: When Medicare officials postponed implementing a new anti-markup rule late last month, it did so because of questions about how the new rule will be applied. However, the Centers for Medicare & Medicaid Services (CMS) did implement an aspect of the anti-markup rule on Jan…

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Are Feds Ready to Strike at TC/PC Arrangements?

CEO SUMMARY: Pathologists and laboratory directors will want to pay attention to the proposed rules published by the Centers for Medicare and Medicaid Services on July 2, 2007. The document is a grab bag of proposals and rules that would significantly curb many common ancillary services a…

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Technical/Professional Billing Has Risks for Labs, Doctors

IT’S A HOT TOPIC ACROSS THE ANATOMIC PATHOLOGY PROFESSION. Increasing numbers of physician groups are hiring laboratories to perform the technical component of an anatomic pathology case and engaging pathologists to diagnose the cases. This phenomenon is often called TC/PC, to repr…

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Technical/Professional Billing Split Is A Threat to Pathology

EACH SECOND YEAR, when we publish our bi-annual trends in anatomic pathology, we get feedback from our clients and regular readers. This year, a particularly insightful letter was received. The writer wants to add another trend to our list of 11. He puts forth his arguments in the letter we reproduc…

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Barristers Offer Insights Into OIG Opinion 04-17

CEO SUMMARY: This is an intelligence briefing which tries to “read between the lines” and: 1) provide useful information about the OIG’s “undeclared” views on physician self-referral issues, particularly as they relate to anatomic pathology condominiums; and, 2) how specialist p…

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Bi-Annual Look at Trends Reshaping Clinical Labs

CEO SUMMARY: Among other things, we declare the end to the heyday of the independent commercial lab company which offers a broad test menu to all types of office-based physicians. In its place springs forth the specialty or niche testing laboratory. Small and focused on a specific number …

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OIG Releases Opinion On AP Lab Condominiums

CEO SUMMARY: In responding to a request for an advisory opinion, the Office of the Inspector General (OIG) issued an advisory opinion which declares that anatomic pathology (AP) lab condominiums “could potentially generate prohibited remuneration under the anti-kickback statute.” It a…

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Analysis of OIG’s Opinion Shows Compliance Shift

CEO SUMMARY: Attorney Richard Cooper believes the latest Advisory Opinion by the Office of the Inspector General (OIG) is consistent with its earlier anti-kickback law pronouncements about situations where a physician is in a position to profit from the patients he/she refers. Cooper also…

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