Dear Chairman Neal, Ranking Member Brady, Chairman Pallone, and Ranking Member Walden:
The undersigned organizations write to express our strong opposition to H.R. 2143, the “Promoting
Integrity in Medicare Act.” If enacted, this legislation would severely limit patient access to life saving services provided within coordinated care models as well as further fragment the healthcare
delivery system during the transition to value-based payments and alternative payment models
(APMs).
The in-office ancillary services exception (IOASE) allows clinicians to provide some services in the
office setting, including advanced diagnostic imaging (MRI, PET, and CT scans), radiation therapy,
anatomic pathology, and physical therapy, when complex and detailed supervision, location, and
billing regulatory requirements are met. In the case of diagnostic studies, in-office access to these
services can facilitate immediate diagnosis and help deliver rapid, appropriate treatment of a
disease condition, in a setting that is more convenient, comfortable and familiar to a patient. The
benefit of providing these medical services in the physicians’ office setting is not limited to
facilitating diagnoses; integration of these services facilitates the development of coordinated care
models, improves communication between clinicians, offers better quality control of ancillary
services and enhances data collection – all of which improves patient care and maximizes efficiencies.
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