A new twist on IOP

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AZpath

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Dermatologists in my area sold out to a venture capital company that specializes in buying small practices. (Many of the practices are 1-3 providers.)
Most had no pathology in house. Now they send all there work to an " IOP lab".

The path lab is in a centralized location in another state owed by the practice.
That's a new one on me. Medicare rule makers likely never anticipated this scenario.
The last IOP rules were put out around 2008 to address pod labs. I think this is legal currently.


Btw, it is doing pretty good on their contracts. They fowarded an AZ patient and Texas BCBS approved payments at 4 x medicare.

I can't get 1.25x MC for Arizona BCBS. I have the EOB so this is real.

I guess everything is really bigger in Texas after all.

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Forefront has been buying up the derms in my region. Path lab is in Wisconsin I believe. It has left a mark on many local path groups. Huge volume heading out of state.
 
Wonder if there is some sort of Stark law violation because it states that "you have to perform the interpretations in a location where each of the referring physicians provides substantially the full range of his or her services to patients." With that said, I am pretty sure you can get away with performing interpretations at a central location. If you want to bill TC, that might be an entirely another story all together... that's what pricey healthcare legal counsel is for, right?
 
Wonder if there is some sort of Stark law violation because it states that "you have to perform the interpretations in a location where each of the referring physicians provides substantially the full range of his or her services to patients." With that said, I am pretty sure you can get away with performing interpretations at a central location. If you want to bill TC, that might be an entirely another story all together... that's what pricey healthcare legal counsel is for, right?

I believe there are two safe harbors
Either location of full range of service

Or

The pathologist does at least 75% of professional services for the practice
 
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