Corporate Compliance

Tip: Transmittal 66

Compliance Monitor, June 13, 2007

Transmittal 66, "Services Not Provided in the U.S.," amends Chapter 16, Section 60 of the Medicare Benefit Policy Manual to add the following paragraph:

"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."

Understand that the payment limitation only applies to the portion of a service furnished outside the United States. CMS says the payment limitation does not apply to technical component radiology services furnished entirely within the United States, even if some portion of the professional component was performed outside the United States, so long as the hospital billed separately for the technical component only.

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