In an MLN Matters announcement, a copy of which is attached at the Link below, CMS has added False Claims Act implications to reporting purchased technical components of diagnostic services. While admittedly any intentional misreporting of the purchased services would be subject to False Claims Act implications, CMS has taken the uncertainly out of this matter by stating that all services will be presumed not to be purchased technical services unless reported otherwise. Therefore, if Block 20 on the 1500 form was blank before, there might have been the argument the service was not reported incorrectly. However, now that all claims presume the technical services have not been purchased, failing to report it as a purchased service will clearly be a false claim, at least under this administrative policy.
http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM6122.pdf
