Can an Urgent Care Provide X-Rays for Other Providers?

Alan Ayers, MBA, MAcc, President, Urgent Care Consultants

Unlocking New Revenue from Ancillary Services

As an urgent care operator, maximizing utilization of your assets is key to success. Your on-site X-ray suite is a significant investment, but what if you could leverage it beyond your own patient base to serve neighboring practices, like a nearby primary care physician (PCP)? This is a common scenario, but it raises important questions about workflow, billing, and compliance, especially when the urgent care (UC) and PCP operate under different tax IDs.

A frequent question is whether a PCP’s patient must be registered and evaluated by a UC provider just to get an X-ray. This creates a clunky workflow, a poor patient experience, and potential billing headaches. For instance, it could trigger an unnecessary UC copay and conflict with payer contracts that bundle imaging services with a full evaluation and management (E/M) service.

A more elegant and compliant solution is the purchased diagnostic test model.

In this arrangement, the UC provides only the technical component (TC) of the X-ray service on behalf of the PCP. The workflow

is streamlined:

  1. The PCP orders the study and remains the treating physician, retaining clinical responsibility.
  2. The UC performs the imaging-only service without a separate E/M visit or copay collection.
  3. The PCP bills the payer for the X-ray, and the UC simply invoices the PCP monthly at a fair-market value (FMV) rate for each study performed.

To implement this correctly, a formal services agreement is essential. This agreement protects both parties and ensures compliance with regulations like Medicare’s anti-markup rule. A comprehensive checklist for drafting this agreement should define crucial terms, including:

  • Parties and Purpose: Clearly identifying the UC as the TC provider for the PCP.
  • Billing and Compliance: Establishing FMV rates that do not vary by referral volume and outlining how the PCP will bill payers.
  • Clinical Responsibility: Confirming the PCP obtains necessary pre-authorizations and communicates results to the patient.
  • Operations: Defining image storage, PACS access, and turnaround time expectations.

By structuring a purchased-test relationship, you can transform your X-ray suite from a cost center supporting only your UC into a revenue-generating asset that serves your medical community.

Structuring these arrangements properly is crucial for compliance and profitability. If you have questions about urgent care planning and operations, schedule a discovery call today.

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