On July 2, 2007, the Centers for Medicare and Medicaid Services ("CMS") posted on its website the proposed updates to the Medicare Physician Fee Schedule ("MPFS") for 2008, which, in addition to a sharp 9.9 percent decrease in payment, include a number of significant revisions to the IDTF performance standards, purchased diagnostic test rule and the physician self-referral prohibition that have the potential to significantly impact certain types of physician-owned imaging ventures.  This memorandum summarizes the proposed updates and discusses the potential impact of the proposed rules on diagnostic imaging arrangements.  We have included "blacklined" versions of the proposed regulatory changes to assist the reader's understanding of the proposed rules. 

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