New Disclosure Requirements Effective January 1, 2011
By Cheyenne Brinson, MBA, CPA
KarenZupko and Associates, Inc.
Attention hand surgeons, if you have in-office MRI, CT, or PET read on. Effective January 1, 2011, you must disclose to your patients a list of five alternate suppliers for each order you make, and that is for each order.
According to the Federal Register Vol. 75, No. 228, dated Monday, November 29, 2010, the new disclosure requirements stipulate:
- Provide the name, address, and phone number of the five alternative providers within a 25 mile radius of the physician’s office. The five alternative providers do not include hospitals, unless there are no other providers available. Hospitals may be included on the list, but cannot be included to make the minimum five providers.
- Notification must be in writing
- No requirement that the patient sign the form. However, physicians should be able to document or otherwise establish that they have complied with the disclosure requirement.
If you’re using an EMR, have the disclosure print at the same time the order for an MRI, CT or PET is made. Have the nurse or medical assistant give the disclosure to the patient at that time and document it in the EMR. Ask your vendor about adding a “check box” to document the workflow and that the disclosure was given to the patient.
If you don’t have an EMR, have the staff person who schedules the ancillary testing provide the patient with the disclosure. Have the patient sign the disclosure and maintain a copy of the disclosure in the same manner you maintain copies of the HIPAA privacy disclosures. Ask your practice management system vendor about adding a “check box” to the patient registration screen for the staff to check once the disclosure is given. However, remember that the disclosure must be given each time a MRI, CT or PET is ordered, so one patient may have several disclosure forms given to them in one year.
Want to read the entire source documentation?
Go to http://edocket.access.gpo.gov/2010/pdf/2010-27969.pdf and it’s pages 73443 – 73447.
Below is a sample disclosure form:
Practice Name and Logo
Practice name owns and operates (MRI, CT, PET) located at address and provides these services for the convenience of our patients.
Effective January 1, 2011, we are required to provide you with the name of five alternate suppliers within a 25 mile radius of our location. In accordance with this requirement, the following suppliers who are not affiliated with our practice offer (MRI, CT, PET) services:
(Note: Do not list the hospital to meet the minimum of five suppliers unless there are fewer than five within a 25 mile radius. You may list the hospital as sixth supplier if you choose. If there are fewer than five suppliers, list all of the suppliers in the 25 mile radius)
Practice name (MRI, CT, PET) located at address office hours are _____ and can be reached at __________.
I have been provided a list of five alternate suppliers for MRI, CT, PET.
Patient Signature Date
About the Author
Ms. Brinson is a practice management consultant and speaker with KarenZupko & Associates who helps physician practices build solid internal controls, reduce overhead, and increase revenue.
Author Contact Information
Cheyenne Brinson, MBA, CPA
Consultant and Speaker, KarenZupko and Associates, Inc.
625 N. Michigan Avenue, Suite 2225, Chicago, IL 60611
(312) 642-5616 ext 220