| The 2008 Medicare Physician Fee Schedule (MPFS) | | | | Anti-Markup Rule |
| was published in the Federal Register on | | | | The final anti-markup rule is effective January 1, |
| November 27, 2007. For the most part, the 2008 | | | | 2008. Without limitation, physicians who provide |
| MPFS final rule will take effect January 1, 2008. | | | | diagnostic testing to their patients and physicians |
| This article will focus on two areas of the MPFS | | | | that contract with radiologists and cardiologists to |
| final rule that will significantly impact diagnostic | | | | provide the reading and interpretation of such |
| testing arrangements: (1) a newly expanded | | | | diagnostic tests may be significantly impacted by |
| anti-mark-up rule and (2) a sharing prohibition for | | | | the final rule (even if the arrangement complies |
| certain independent diagnostic testing facilities | | | | with Stark). All physicians that currently provide |
| (IDTFs). The changes in these areas will | | | | these services must have their arrangements |
| significantly impact the structuring of common | | | | reviewed to ensure compliance with the new rule. |
| physician diagnostic testing arrangements. | | | | Failure to comply with the final rule may create |
| Who May be Impacted by the January 1, 2008 | | | | false claims liability. |