What is the purpose of a comparative billing report (CBR) on Independent Diagnostic Testing Facilities (IDTFs)?
CBR201806 was created to inform providers about their referrals to IDTFs and to see how their patterns compare to their peers. The CBR team analyzed Fee-for-Service (FFS) Medicare Part B claims with dates of service from January 1, 2017 to December 31, 2017. If you would like more general information about CBRs, please visit our website at the link titled, Comparative Billing Reports.
Why was IDTFs chosen as a CBR topic?
This topic was selected as a CBR because improper payment rates are high for Medicare Part B IDTFs. Each year, the Comprehensive Error Rate Testing (CERT) program calculates the Medicare FFS improper payment rates. According to the 2017 CERT report, insufficient documentation errors were listed as the top cause of improper payments. To view this report, select the following web link: 2017 Medicare Fee-for-Service Supplemental Improper Payment Data.
Did I receive a CBR because I am referring my patients incorrectly?
It does not mean your referrals are incorrect just because you received a CBR; however, it does mean that your referral patterns are different from your peers. Your referral patterns may vary because of your region, subspecialty, and/or patient acuity. If you still have questions and/or concerns after reviewing your CBR, please contact the CBR Support Help Desk by telephone at 1-800-771-4430 or by email at CBRSupport@eglobaltech.com.
Where can providers find additional information about CBR201806?
Providers may benefit from the explanations of the tables in the CBR, which are found at the web link, CBR201806 Statistical Debriefing. Additionally, the links for the references and resources used in this CBR are located at CBR201806 Recommended Links.
Who is responsible for ordering procedures performed at IDTFs?
According to the Electronic Code of Federal Regulations (e-CFR Title 42, 410.33), procedures that are done by an IDTF “must be specifically ordered in writing by the physician who is treating the beneficiary…for a specific medical problem and who uses the results in the management of the beneficiary's specific medical problem.”
Can the supervising physician of an IDTF order tests?
A supervising physician of an IDTF “may not order tests to be performed by the IDTF, unless the IDTF's supervising physician is in fact the beneficiary's treating physician. That is, the physician in question had a relationship with the beneficiary prior to the performance of the testing and is treating the beneficiary for a specific medical problem. The IDTF may not add any procedures based on internal protocols without a written order from the treating physician.” This information can be found at the following web link: e-CFR Title 42, 410.33
What are the criteria for physicians who supervise IDTFs?
Supervising physicians must be licensed to practice in the State(s) where tests are performed, be enrolled in Medicare, and meet proficiency tests that they supervise. Additionally, each physician cannot supervise more than three IDTF sites and must not be currently excluded or barred. For complete information, see the e-CFR Title 42, 410.33.
Can IDTF physicians use the same credentials for services performed across State boundaries?
According to a Medicare Learning Network (MLN) publication, IDTFs must “maintain documentation that its supervising physicians and technicians are licensed and certified in each of the States in which it operates.” For more information about licensing and credentialing, select the following MLN web link: Independent Diagnostic Testing Facility (IDTF) Fact Sheet.
What are the responsibilities of a supervising physician?
Each IDTF “must have one or more supervising physicians who are responsible for:
- The direct and ongoing oversight of the quality of the testing performed
- The proper operation and calibration of equipment used to perform tests and
- The qualifications of non-physician IDTF personnel who use the equipment”
Each supervising physician does not have to be responsible for all of the supervising functions, but all supervisory functions must be met at each IDTF location. For additional information, select this web link: IDTF Fact Sheet.
Is an IDTF required to have an interpreting physician on staff?
According to the IDTF Fact Sheet, Medicare does not require an IDTF to have an interpreting physician; however, “if the IDTF does have such physicians, the IDTF interpreting physician must:
- Be licensed to practice in the State(s) where the diagnostic tests he or she supervises will be performed
- Be enrolled in Medicare
- Not be currently excluded or barred
- Be qualified to interpret the types of test (codes) listed in the enrollment application”
Can some IDTF services be done without a doctor’s visit?
Some monitoring services classified as IDTF may be performed without a physician actually seeing the patient. These include transtelephonic and electronic monitoring services (e.g., cardiac event detection, 24-hour ambulatory electrocardiogram monitoring, and pacemaker monitoring). These types of IDTFs require a supervisory physician. A site visit is also required prior to final enrollment of a transtelephonic or electronic monitoring service as an IDTF. More information can be found at the following web link: Medicare Claims Processing Manual (Chapter 35, Section 10.2).
Can IDTFs share equipment with other Medicare-enrolled providers?
Hospital-based and mobile IDTFs may share equipment; however, fixed-based IDTFs are not allowed to share diagnostic testing equipment with other Medicare providers. Also, a fixed-based IDTF cannot share a practice location, or lease/sublease its practice to another Medicare-enrolled provider.
When can a new IDTF begin receiving payment for services?
The IDTF Fact Sheet states “billing privileges for a newly enrolled IDTF is the later of the following:
- The filing date of the Medicare enrollment application that was subsequently approved
- The date the IDTF first started furnishing services at its new practice location. A newly enrolled IDTF, therefore, may not receive reimbursement for services furnished before the effective date of billing privileges.”
What were the criteria for receiving CBR201806?
Our analysis of claims found that more than 268,000 providers nationwide have referrals for IDTFs, and the report was sent to approximately 9,700 of these referring providers. The criteria for receiving this CBR were as follows:
- Provider was significantly higher than at least one of the peer groups on at least two of the metrics studied
- Provider was above the 75th percentile in allowed charges ($5,000) for referrals
- Provider had referrals for at least 10 beneficiaries
How was the data obtained for this report?
This report is an analysis of providers listed as the “Referring NPI” on Medicare Part B claims. Claims with dates of service January 1, 2017 to December 31, 2017 were drawn from the Integrated Data Repository (IDR) on May 16, 2018. This analysis included claims with a rendering specialty of IDTF (specialty 47). For more information about the IDR, see the following link: CMS Integrated Data Repository (IDR).
What do the comparison outcomes mean?
The four possible outcomes for the comparisons between the provider and peer groups are:
- Significantly Higher - provider’s value is higher than the peer value and the statistical test used confirms significance
- Higher - provider’s value is higher than the peer value, but the statistical test does not confirm significance
- Does Not Exceed - provider’s value is not higher than the peer value
- N/A (Not Applicable) - provider does not have sufficient data for comparison
What is the meaning of Table 1?
Table 1 is a summary of a provider’s referrals to IDTFs. It includes the number of services, the number of beneficiaries, and the total charges for services performed from January 1, 2017 to December 31, 2017. To review an example of a referring provider’s report, select the web link at CBR201806 Sample CBR.
What does Table 2 show?
Table 2 shows the percentage of services submitted without a visit to the referring provider within 90 days prior to the IDTF service. To see a sample report, select this web link: CBR201806 Sample CBR.
How were the visits to the referring provider within 90 days determined?
For each IDTF service, the referring providers claims were searched to determine if the beneficiary listed on the IDTF claim had any Part B services with the referring provider in the 90 days prior to the service date of the IDTF claim.
What’s the significance of Table 3?
Table 3 gives the percentage of services without a similar diagnosis within 90 days prior to the IDTF service date. All diagnoses submitted on Medicare Part B claims, from all providers with service dates within 90 days prior to the IDTF service date, were compared to the line diagnosis on the IDTF claim. Claims with the same Diagnosis Related Group (the first three digits of the diagnosis) were considered similar diagnoses. An example of this table can be viewed in the sample CBR at CBR201806 Sample CBR.
How should providers interpret Table 4?
Table 4 shows the average allowed charges per beneficiary that were referred to an IDTF by the individual provider for the one-year period. This average includes all services referred to one or more IDTFs. An example of this table can be viewed at the following web link: CBR201806 Sample CBR.