Corporate Compliance

Payments for overseas contractors who read radiology films

Compliance Monitor, June 8, 2007

Q: Our hospital contracts with a radiology group that provides credentialed physicians from overseas to read radiology films in the middle of the night. I have heard that there is a new Medicare transmittal that states the reading and the film are not covered when the reading takes place outside the United States. Is this true?

A: Yes, this is true. CMS released Transmittal 66, Change Request 5427, ("Services Not Provided Within United States") on February 23, 2007. Transmittal 66 has an effective date of November 13, 2006, and an implementation date of April 2, 2007.

You can find Transmittal 66 at the CMS Web site: www.cms.hhs.gov/Transmittals/Downloads/R66BP.pdf. It states the following:

Payment may not be made for a medical service (or a portion of it) that was subcontracted to another provider or supplier located outside the United States.  For example, if a radiologist who practices in India analyzes imaging tests that were performed on a beneficiary in the United States, Medicare would not pay the radiologist or the U.S. facility that performed the imaging test for any of the services that were performed by the radiologist in India.

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