F. X-ray and EKG interpretation

When a hospital radiologist does the initial interpretation of a radiological exam which the hospital radiologist or a qualified technician performed on a hospital patient, the interpretation is clearly covered as a physician's service. In addition, when a hospital radiologist interprets an X-ray that has already been interpreted by another physician, that interpretive service almost always constitutes patient care and, thus, would also qualify as a physician's service. The radiologist's interpretation is a specialist's evaluation of the interpretation of the attending physician or the emergency room physician, and the radiologist's findings could affect the course of treatment initiated or cause a new course of treatment to begin. The fact that the particular patient is no longer on the hospital premises at the time the radiologist interprets the X-ray should not be controlling in deciding whether there was a physician's service, since the patient may be recalled. If, on the other hand, the radiologist is interpreting the X-ray solely for “quality control” purposes, e.g., randomly selecting films to appraise the technician's performance, quality of the film or equipment, the service should be considered a hospital service reimbursable under Part A of the Medicare program. These same rules would apply to a cardiologist's diagnostic interpretations previously interpreted by an attending or an emergency room physician.

Part of an attending/emergency room physician's overall workup or treatment of a patient would include the interpretation of an X-ray or EKG ordered by the attending/emergency room physician. Thus, a separate charge would not be allowed for an X-ray or EKG interpretation performed by the attending physician after the hospital's radiologist's or cardiologist's interpretation (including in those terms any physician working in either capacity).