Compliance Alert for Providers Operating as Independent Diagnostic Testing Facilities

The Florida Medicaid program does not enroll or reimburse for the services performed by an Independent Diagnostic Testing Facility (IDTF). Medicaid policy allows physicians practicing in an IDTF to enroll as a physician group so that they may only bill Medicaid for the professional component when services are rendered at the IDTF. Florida Medicaid does not reimburse for the technical component or global fee for services performed by an IDTF. This is not a new policy and it applies to both physician-owned and non-physician-owned IDTFs. This notice is being provided to you in anticipation of Agency-conducted audits regarding this policy.

If your practice is performing diagnostic testing, the global fee (or technical component) is only properly reimbursed when your practices’ physicians are also the treating providers (for the patient’s condition that warranted the testing). Physician practices that do not include the treating provider should immediately stop billing Medicaid for the global fee and/or technical component for diagnostic testing. Also, providers may choose to voluntarily conduct a self-audit and repay any overpayments prior to an Agency-conducted audit. When the Agency conducts an audit, it is entitled to recover the costs of the audit and is required to assess sanctions for the non-compliance.

It is recommended that you review claims from January 1, 2011, to present and submit self-audit findings as well as a refund check to the Agency for any improper payments detected in the audit. A provider who conducts a self-audit, submits the results, and remits payment, may avoid sanctions for the voluntary disclosure and repayment of overpayments. Information about conducting self audits, as well as the contact information for your local area office, is available on the agency’s website.

Questions specific to the anticipated recoupment project may be directed to Kelly Bennett via email at Please include the question in the email as opposed to a request for a return phone call.

Supervisory Requirements for IDTFs

supervisionWe get questions all the time regarding the supervisory requirements for Independent Diagnostic Treatment Facilities (IDTF). Here are some tips in complying with one of the key elements in obtaining and maintaining status as an IDTF and as a Medicare provider.

An 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. Not every supervising physician has to be responsible for all of these functions. One supervising physician could be responsible for operation and calibration of equipment, while other physicians are responsible for test supervision and the qualifications of non-physician personnel. Continue reading