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Jean M. Mitchell The Prevalence Of Physician Self-Referral Arrangements After Stark II: Evidence From Advanced Diagnostic Imaging Health Affairs, May/June 2007; 26(3): w415-w424. [Abstract] [Full Text] [Figures Only] [PDF] [Reprints & Permissions]

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Limited Implications

Robert G. Burney, M.D.   ( 17 April 2007 )

Self-Referral/Equality for All Physicians?

Harlan R. Weinberg, MD, FCCP   ( 18 April 2007 )

Exploitation or Intention?

Bradford Kirkman-Liff   ( 18 April 2007 )

Appropriateness Of Imaging Services Needs To Be Explored

Timothy Trysla   ( 25 April 2007 )

Simplistic View

Robert Varipapa   ( 13 June 2007 )

Limited Implications 17 April 2007
Robert G. Burney, M.D., Director, Quality Improvement U.S. Department of State Send comment to journal: Re: Limited Implications burneyrg{at}state.gov Robert G. Burney, M.D.	The authors have established that nonradiologists occasionally refer patients to facilities where they have a financial interest. They have not established that this is improper. To do so would require answers to two additional questions: 1. Was the study an acceptable diagnostic test for this patient? 2. Was the charge for the study less than or equal to that for any other facility in the area? If the answer to both questions is "yes," then there is no problem. If "no," then we also have to ask why the insurers authorized payment. Certainly, the exemption for surgery centers resulted in better and cheaper care for patients. Perhaps this is true for diagnostic imaging patients also. Why were smaller practices targeted? I would guess that abuse is more common in larger facilities (e.g. university hospitals) that own both the equipment and the referring physicians.
Self-Referral/Equality for All Physicians? 18 April 2007
Harlan R. Weinberg, MD, FCCP, Director, ICU Northern Westchester Hospital Send comment to journal: Re: Self-Referral/Equality for All Physicians? hrwstm{at}aol.com Harlan R. Weinberg, MD, FCCP	How fair is it that medical groups may refer their patients to their own lab and radiology facilities but those physicians who are in independent practice are unable to do the same, in those free-standing facilities? Also, the independent physicians receive no fee for any of their referrals, unlike fee distributions in the medical groups. The time has come for equal compensation on those professional services provided by MDs.
Exploitation or Intention? 18 April 2007
Bradford Kirkman-Liff, Professor School of Health Management and Policy, W. P. Carey School of Business, Arizona State University Send comment to journal: Re: Exploitation or Intention? bradford.kirkman.liff{at}asu.edu Bradford Kirkman-Liff	The "deck" of Jean Mitchell's article was as follows: "Data from California suggest that physicians exploit exceptions in the Stark II law to continue to self-refer patients for imaging." I suspect that in the legislative process there were various compromises made along the route. The exceptions that were placed in Stark II were not innocent exceptions. They were intentionally designed to create a kind of "win-win" situation in which the advocates for controlling the diffusion of new technology and limiting self-referral could appear to have restricted this practice while the physicians, the manufacturers of diagnostic technologies, the banks and others who finance these investments, and the attorneys and consultants who organize these ventures could continue their businesses. And the inevitable Stark III? It will contain other loopholes that will be exploited. The entrepreneurial creativity of American fee-for-service medicine is boundless. Only changing the fundamental incentives will cause physician self-referral to be moderated.
Appropriateness Of Imaging Services Needs To Be Explored 25 April 2007
Timothy Trysla, Counsel Access to Medical Imaging Coalition Send comment to journal: Re: Appropriateness Of Imaging Services Needs To Be Explored timothy.trysla{at}alston.com Timothy Trysla	We have reviewed the article in Health Affairs on equipment leasing and are hopeful that the author will release the underlying study data so that her peers can replicate her analysis. Since its inception, the Access to Medical Imaging Coalition (AMIC) has worked with policymakers with the goal of ensuring appropriate utilization of medical imaging services. Unfortunately, the Health Affairs article does not offer any data on the appropriateness of the imaging procedures it analyzes -- which is the key to crafting responsible and sustainable policies on access to medical imaging services. Without having access to the author's data, it is impossible to know if the conclusions she has drawn are reflective of the facts. However, if the arrangements described in the Health Affairs article are in violation of federal or state law, those violations of the law should be prosecuted. AMIC looks forward to continuing to work with the Congress to enact a reasonable Medicare imaging policy that preserves and strengthens beneficiary access to the right imaging procedure at the right time.
Simplistic View 13 June 2007
Robert Varipapa, Staff Neurologist CNMRI Send comment to journal: Re: Simplistic View robert.varipapa{at}cnmri.com Robert Varipapa	I believe this article takes a simplistic, one-sided look at self-referral. Our private practice group has had MRI services since 1987, and we feel that we are saving health care costs. Two primary reasons: 1. Third-party insurers pay us much less than the local hospital system; 2. In-office MRI expedites diagnosis and reduces hospitalization rates. Abuses of the system should be curbed but not in a way that monopolizes services and prevent unique practice arrangements that foster excellent patient care.