Independent Diagnostic Testing Facility (IDTF)

The following provides guidance regarding the types of entities that may or may not be sufficiently independent from a physician office or hospital to require enrollment as an independent diagnostic testing facility (IDTF). An entity generally should not be considered independent from a physician office or hospital if it has the following characteristics:

  • It is a physician practice that is owned, directly or indirectly, by one or more physicians or by a hospital
  • The entity primarily bills for physician services (e.g., evaluation and management (E/M) codes) and not for diagnostic tests
  • It furnishes diagnostic tests primarily to patients whose medical conditions are being treated or managed on an ongoing basis by one or more physicians in the practice
  • The diagnostic tests are performed and interpreted at the same location where the practice physicians also treat patients for their medical conditions



Brief Description

Ambulatory Surgical Centers (ASCs)


Cannot bill for separate diagnostic tests it performs during ASC scheduled hours of operation (see 42 CFR 416.2). If an entity, which owns an ASC, performs diagnostic tests in same physical facility as ASC but during a time period when ASC is not in operation, those diagnostic tests can be billed by an enrolled IDTF; therefore, in that instance, an additional separate enrollment by the entity as an IDTF is required

Cardiac Catheterization Facilities


Can be set up either as a physician-directed clinic or an IDTF; however, an IDTF may not bill for interpretation of cardiac catheterization procedures. Cardiac catheterization procedures must be split billed (e.g., TC modifier/26 modifier) as they are not ‘diagnostic tests.'

  • Physician must bill for professional component (26 modifier) of cardiac catheterization services rendered
  • Facility must bill technical component (TC modifier) of procedure code for facility fee reimbursement



To be exempt from IDTF standards and enrollment as an IDTF, because applicant is a part of a hospital, applicant should be provider-based in accordance with Section 404 of Medicare, Medicaid and SCHIP Benefits Improvement and Protection Act of 2000, Publication L, Number 106–554. Diagnostic tests billed by hospital to its own patients, which are performed under arrangement, do not require IDTF billings and therefore do not require IDTF enrollment; however, if entity providing under-arrangement diagnostic tests perform diagnostic tests that will be billed under its own billing number (not the hospital's), entity is subject to IDTF rules. Therefore, entity may or may not require enrollment as an IDTF for its own patients. An entity can be enrolled as an IDTF (it is considered independent) if it requires IDTF enrollment as stated above. This is the case even if there is joint ownership with hospital, if entity is located on hospital campus, or if it cannot qualify as provider-based

Mobile Units


Required to list their geographic service areas. A supervisory physician performing direct or personal supervision for IDTF on a patient should be aware of prohibition concerning physician self-referral for testing

Slide Preparation Facilities


Not IDTFs. These are entities that provide slide preparation and other types of services that are payable through the technical component of the surgical pathology service. They do not provide professional component of surgical pathology services or other laboratory tests. The services they provide are recognized by carriers for payment as codes in the surgical pathology CPT code range 88300 - 88399 with a technical component value under Medicare Physician Fee Schedule (MPFS). The services provided by these entities are usually ordered and reviewed by a dermatologist. Slide preparation facilities generally only have one or two people performing this service.

Radiology Groups


Many diagnostic tests are radiological procedures that require professional services of a radiologist. A radiologist's practice is generally very different from those of other physicians because radiologists usually do not bill E/M codes or treat a patient's medical condition on an ongoing basis. Nevertheless, a radiologist or a group of radiologists should not necessarily be required to enroll as an IDTF.

The following features would indicate that a radiology practice is not independent from a physician office or hospital: 

  • Practice is owned by radiologists, a hospital or both
  • Owner radiologists and any employed or contracted radiologists regularly perform physician services (e.g., test interpretations) at location where diagnostic tests are performed
  • Billing patterns of enrolled entity indicate entity is not primarily a testing facility and that it was organized to provide professional services of radiologists (e.g., enrolled entity should not bill for a significant number of purchased interpretations, it should rarely bill only for technical component of a diagnostic test, and it should bill for a substantial percentage of all of interpretations of diagnostic tests performed by practice) 
  • Substantial majority of radiological interpretations are performed at practice location where diagnostic tests are performed

Radiation Therapy Centers

Not IDTFs. They provide therapeutic services




Brief Description

Clinical Laboratory Improvement Act (CLIA) Tests

Cannot be performed or bill for by an IDTF; however, an entity with one Tax Identification Number (TIN) may own both an IDTF and an independent CLIA laboratory. Should be separately enrolled and should bill separately

Diagnostic Mammography Services

If an IDTF performs diagnostic mammography, it must have a Food and Drug Administration (FDA) certification to perform mammography; however, an entity that only performs diagnostic mammography should not be enrolled as an IDTF

Portable X-ray Services


A mobile IDTF that provides X-ray services is not classified as a portable X-ray supplier; therefore, it cannot bill for transportation (HCPCS code R0070) and setup (HCPCS code Q0092). If it desires to bill for these services, it must also enroll, qualify and bill as a portable X-ray supplier in accordance with portable X-ray supplier billing rules.

Note: Portable X-ray suppliers are certified by state

Transtelephonic and Electronic Monitoring Services (e.g., 24-hour ambulatory EKG monitoring, pacemaker monitoring and cardiac event detection)

May perform some of their services without actually seeing patient. Most, but not all, of these billing CPT codes are 93041, 93224, 93225, 93226, 93268, 93270, 93271, 93280, 93283, 93288, 93289, 93293, 93294, 93295, 95950, 95951, 95953 and 95956. These monitoring service entities are considered IDTFs and must meet all IDTF requirements. The entity actually must have a person available 24 hours a day to answer telephone inquiries. Use of an answering service in lieu of actual person is not acceptable. The person performing attended monitoring should be listed in Form CMS 855 B, Attachment 2, Section 3. The qualifications of person are at carrier's discrection 



Last Updated Nov 23, 2015