Thursday, 10 November 2016

Clinical Social Workers / Multi-State Independent Diagnostic Testing Facilities (IDTFs) / Interpreting Physicians

Clinical Social Workers

Federal regulations at 42 CFR §410.73(a) defines a clinical social worker as an individual who:

1. Possesses a master's or doctor's degree in social work;

2. After obtaining the degree, has performed at least 2 years of supervised clinical social work; and

3. Either is licensed or certified as a clinical social worker by the state in which the services are performed or, in the case of an individual in a state that does not provide for licensure or certification as a clinical social worker—

a. Is licensed or certified at the highest level of practice provided by the laws of the state in which the services are performed; and

b. Has completed at least 2 years or 3,000 hours of post master's degree supervised clinical social work practice under the supervision of a master's degree level social worker in an appropriate setting, such as a hospital, SNF, or clinic.

For more information on clinical social workers, refer to Pub. 100-02, Medicare Benefit Policy Manual, Chapter 15, section 170.

Multi-State Independent Diagnostic Testing Facilities (IDTFs)

As stated in 42 CFR § 410.33(e)(1), an IDTF that operates across State boundaries must:
• Maintain documentation that its supervising physicians and technicians are licensed and certified in each of the States in which it operates; and
• Operate in compliance with all applicable Federal, State, and local licensure and regulatory requirements with regard to the health and safety of patients.
The point of the actual delivery of service means the place of service on the claim form. When the IDTF performs or administers an entire diagnostic test at the beneficiary's location, the beneficiary’s location is the place of service. When one or more aspects of the diagnostic testing are performed at the IDTF, the IDTF is the place of service.

Interpreting Physicians

The applicant shall list all physicians for whose diagnostic test interpretations it will bill. This includes physicians who will provide interpretations subject to the anti-markup payment limitation as detailed in CMS Publication 100-04, chapter 1, § 30.2.9 - whether the service is provided to the IDTF on a contract basis or is reassigned.

The contractor shall ensure and document that:

• All listed physicians are enrolled in Medicare

• All interpreting physicians who are reassigning their benefits to the IDTF have the right to do so

• The interpreting physicians listed are qualified to interpret the types of tests (codes) listed. (The contractor may need to contact another contractor to obtain this information.) If the applicant does not list any interpreting physicians, the contractor need not request additional information because the applicant may not be billing for the interpretations; that is, the physicians may be billing for the interpretation themselves.

If an interpreting physician has been recently added or changed, the new interpreting physician must have met all of the interpreting physician requirements at the time any tests were performed.
A Form CMS-855R need not accompany a Form CMS-855B application submitted by an independent diagnostic testing facility (IDTF) that employs or contracts with an interpreting physician.

Technicians

Each non-physician who performs IDTF diagnostic tests must be listed. These persons are often referred to as technicians.

A. Licensure and Certification -- All technicians must meet the standards of a state license or state certification at the time of the IDTF’s enrollment. The contractor may not grant temporary exemptions from such requirements.

In lieu of requiring a copy of the technician’s certification card, the contractor may validate a technician’s credentials online via organizations such as the American Registry for Diagnostic Medical Sonography (ARDMS), the American Registry of Radiology Technologists (ARRT), and the Nuclear Medicine Technology Certification Board (NMTCB). If online verification is not available or cannot be made, the contractor shall request a copy of the technician’s certification card.

B. Changes of Technicians
If a technician is being added or changed, the updated information must be reported via a Form CMS-855B change request. The new technician must have met all of the necessary credentialing requirements at the time any tests were performed.

If the contractor receives notification from a technician that he/she is no longer performing tests at the IDTF, the contractor shall request from the supplier a Form CMS-855B change of information. If the provider did not have another technician qualified to perform the tests listed on the current application, the supplier must submit significant documentation in the form of payroll records, etc. to substantiate the performance of the test by a properly qualified technician after the date the original technician was no longer performing procedures at the IDTF.

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