Medicare is proposing that all physician practices providing diagnostic testing must enroll as independent diagnostic testing facilities effective as of September 30, 2009.  A copy of the comments on the proposal is attached.


This proposal would make physician practices subject to the performance standards for independent diagnostic testing facilities.  This will prohibit, or at least discourage, hotel and motel sites, which are described as inappropriate in IDTF standards. 


It would require non-physician personnel performing testing to have licensure or certification.  There are a number of IDTF standards which would not apply to physician practices; one of those is the prohibition against sharing a practice location with another Medicare enrolled organization, which presumably means the physician practice.  However, it still would prohibit leasing or subleasing the operations or the practice location, or sharing diagnostic testing equipment.


I have attached a copy of the comments from the 2009 Medicare Physician Fee Schedule Proposal.  This is only a proposal, but the potential impact is obvious.


The proposals will also require enrollment of entities furnishing mobile services.