The American College of Radiology® (ACR®) has submitted comments to the Centers for Medicare and Medicaid Services (CMS), asking for a revision to the Medicare Benefit Policy Manual to clarify that a radiologist can act as a treating physician and order medically necessary diagnostic tests where the radiologist manages an aspect of the patient’s care, even if the radiologist may refer the patient out for interventional procedures.
Diagnostic tests must be ordered by a treating physician, with the Social Security Act defining “treating physician” as “the physician who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results in the management of the beneficiary’s specific medical problem.” In the Medicare Benefit Policy Manual, CMS has interpreted the treating physician regulation to impose an additional “radiologist-only” restriction. The manual states: “A radiologist performing a therapeutic interventional procedure is considered a treating physician. A radiologist performing a diagnostic interventional or diagnostic procedure is not considered a treating physician.”
An increasing number of radiology practices have the capability and desire to serve a much more active role in managing at least one aspect of patient’s care. Radiologists have unique and specialized training in the optimal performance of radiological procedures and the interpretation of medical images. Having a radiologist directly manage aspects of certain patients’ care can help to ensure the appropriate diagnosis, management and treatment of the patient ailments. Revision to the policy manual is made even more critical due to the current COVID-19 pandemic.
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