CMS (then HCFA) memo regarding X-Ray/EKG Interpretations in the ED

Refer to: FKA 43

JUN 27, 1996

Ms. Roslyne D. W. Schulman
American College of Emergency Physicians
1111 19th Street, NW, Suite 650
Washington, DC 20036-3603

Dear Ms. Schulman,

I am responding to your letter regarding implementation of the Medicare policy on payment for the interpretation of x-rays and EKGs furnished to emergency room patients.

We hope to have carrier instructions out on the emergency room in the next few weeks. While I cannot tell you exactly what those instructions will say, I would like to assure you that it has never been our intent to mandate that a billable interpretation of an x-ray specifically follow the American College of Radiology guidelines. The manual section on the revised policy will specify that the report must be a complete report similar to that usually prepared by a specialist in the field and should be consistent with the service furnished. We plan to indicate that, in addition to a diagnosis, the report should address the findings, relevant clinical issues, and comparative data (when available). However, we do not think that it would be appropriate to require that the interpretation meet all the criteria in the standards established by the American College of Radiology. In keeping with our rationale for changing the policy, we do not want to imply that the only payable report would be one that only a radiologist could write.

Finally, we see no reason why a complete written interpretation cannot be recorded within the emergency department treatment records; therefore, we are not planning to require that the interpretation be written on a separate piece of paper. We might want to revisit such a requirement at a later date, but, currently, we fail to see the benefit of a separate piece of paper.

I hope this information will be helpful to you.


Terrence L. Kay
Division of Physician Services
Office of Physician and Ambulatory Care Policy
Bureau of Policy Development

[ Feedback → ]