ACR's proposal would have significant negative impacts on patient care and create new costly and burdensome regulatory requirements for nuclear cardiology practices.

Currently, IDTF regulations apply to entities that are independent of hospitals and physician offices, but provide the technical component of diagnostic imaging tests. Under the ACR's proposal, only its procedure-specific standards for CT, MRI and PET would be used to determine who qualifies as a supervising physician under any new national IDTF regulatory scheme. Such a move would limit the ability of physician specialists to provide and interpret imaging studies and could cost physicians and the Medicare program more money due to the increase in paperwork for physician offices and the cost of the site visits that the Medicare program would be required to perform.