A radiologist performing a diagnostic or interventional procedure, however, is not considered a treating physician.ĬMS defines an order as a written communication (hand delivered or faxed), telephone call, or e-mail to the testing facility by the treating physician/practitioner or his or her staff. The rules clarify that a radiologist performing a therapeutic interventional procedure is considered a treating physician and thus can order tests related to the condition for which the intervention is being performed. CMS defines a treating physician as a 'physician who furnishes a consultation or treats a patient for a specific medical problem, and who uses the results of a diagnostic test in the management of the patient's specific medical problem,' and a treating practitioner as a 'nurse practitioner, clinical nurse specialist, or physician assistant, pursuant to state law, who furnishes a consultation or treats a patient for a specific medical problem, and who uses the results of a diagnostic test in the management of the patient's specific medical problem.' The treating physician/practitioner must order all diagnostic tests furnished to a patient who is not a hospital inpatient or outpatient. The ACR was successful in lobbying CMS to obtain clarification that this rule does not apply to hospital inpatients or outpatients.

This lack of clarification caused widespread confusion in the industry. This policy was 'intended to prevent the practice of some testing facilities routinely applying protocols which require performance of sequential tests.' It did not specifically differentiate, however, between services performed in the hospital versus nonhospital setting. When first issued, the Ordering of Diagnostic Tests Rule defined the treating physician/practitioner and indicated that all diagnostic tests must be ordered by persons in this category. CMS and the American College of Radiology have clarified the issue in the past, but many facilities still operate in a gray area. The Centers for Medicare and Medicaid Services defines a testing facility as a physician, group of physicians, or independent diagnostic testing facility (IDTF) that furnishes diagnostic tests to Medicare patients. The Ordering of Diagnostic Tests Rule covers imaging tests performed in a testing facility, and the Conditions of Participation: Radiology Service Rules covers hospital inpatients and outpatients. The confusion stems from the fact that there are two sets of rules. Considerable confusion remains in the radiology community surrounding what constitutes a valid order for a diagnostic test and who must generate that order.

Snap diagnostics physician order