Due to confusion surrounding whether an IDTF was considered a “mobile” or “fixed-base” delivery structure, the DAB has explicitly stated that there are two types of mobile IDTFs. Mobile IDTFs can either be “portable units” or a “mobile facility or unit.” The difference between the two definitions is that a “portable unit” is one that transfers equipment to different fixed locations for diagnostic testing, while a “mobile facility or unit” is a vehicle that travels to different locations to treat patients inside the vehicle.
The DAB further clarified that rules on shared practice space between IDTFs and another Medicare enrolled provider. These entities may share a location, but there is a clear distinction between clinical and non-clinical space. The DAB specified that the sharing of common hallways, waiting rooms, and reception areas is permissible. But the sharing of clinical space or diagnostic equipment is still strictly prohibited.
If you have any question or concerns regarding compliance with current CMS regulations, please contact one of our attorneys at 248-544-0888 or visit www.Wachler.com for more information.