This article explores certain provisions of the proposed Medicare physician fee schedule (PFS) regulations released on July 2, 2007. In addition to the proposed fee schedule revisions, the Centers for Medicare and Medicaid Services (CMS) is also using this PFS rulemaking as a vehicle for revisions to the Stark Law regulations and certain rules regarding reassignment and purchased services, Independent Diagnostic Testing Facilities (IDTFs), and services "under arrangements," which individually, and in combination, would limit the options for structuring arrangements for many health care services and require restructuring many existing arrangements that comply with current law. This white paper summarizes the proposals affecting permissible arrangements for health care services and the effect of the proposed regulations on common arrangements across the United States.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.