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MPFS Proposed Rule changes to Stark

Imaging remains under attack on all fronts it seems. CMS suggested in the 2008 Proposed Rule that it may limit the applicability of the in-office ancillary services exception and prohibit use of per click mechanisms where physician-lessors of equipment also refer to the facility-lessee; perhaps more significant, so-called "under arrangements" structures would be constrained or eliminated.

Legislation currently in Congress would replace the current single conversion factor with six - with a lower one for imaging! - and pay for the SCHIP expansion with further reductions in imaging reimbursement.

All of these potential changes increase the risk of future cashflow from Medicare-sourced procedures and need to be considered in an appraisal or valuation.

Report on the Healthcare Economy

Purchasers of my now sold-out book and those who purchase the updated chapter on valuation methods in Adobe .pdf format have received a free copy of my most recent Report on the Healthcare Economy. Many of the statistical studies cited in that Report are released between June and September each year, and as such the new edition is only now available.  It reflects updates from: the Census Bureau's just released report on health insurance, the National Center for Health Statistics reports on Ambulatory Medical Care and Hospital Utilization, MedPAC's 2007 Report to Congress, Physician Utilization and Specialty Distribution, trends in Average Length of Stay, Inpatient Utilization and Cost per Day and Phase 3 of the Stark II regulations, released August 27, 2007. Many of the readers of my book find this helpful in their valuation practice.

Future editions of the Report on the Healthcare Economy will generally be released in November or December after the publication of the final Medicare Physician Fee Schedule Rule by CMS; in February after the publication of the annual National Health Expenditures projections; and again in the Spring.  These are currently available for $20 each; prior editions can also be purchased.