February 28, 2019

ACR Clarifies “Incident to” Billing Rule When RAs Perform Supervised Office-Based Procedures

An advisory issued February 28, 2019 by the American College of Radiology (ACR), in collaboration with imaging technologist and physician extender stakeholders, clarifies Medicare’s “Incident to” rule covering conditions for payment for radiologists providing direct supervision to radiologist assistants (RAs) performing diagnostic or non-diagnostic procedures.

The College issued the recommendations in response to inquiries since enactment of revised supervision rules in the CY 2019 Physician Fee Schedule. The revision recognizes RAs as radiologist staff members and enables them to provide technical component imaging services under direct supervision, without requiring the radiologist to be in the room with the RA and patient as a condition of Medicare payment to either the hospital or radiologist for the technical component of the diagnostic imaging service.

The clarification addresses relevant “incident to” rules and how they apply to RAs in radiology practice for diagnostic and therapeutic services and offers advice on the challenge of determining whether the radiologist can meet the billing requirement for non-diagnostic services provided by the RA in an office setting.

The American Registry of Radiologic Technologists, American Society of Radiologic Technologists and Society of Radiology Physician Extenders assisted with the recommendations.