Quick radiology coding quiz: When a radiology center submits a claim for an MRI performed with contrast, where was the doctor?
 
If the practice is run by law abiding citizens, the answer is “in the office suite” because a physician must provide direct supervision of these services. But according to the Department of Justice, if the practice was owned and run by William Wolf, III and doctors Timothy Greenan and Steven Winter, the doctor might have been anywhere but the office.
 
Wolf and Greenan owned Imagimed, LLC a diagnostic MRI company based in New York; Winter served as the chief radiologist for the company, which runs 15 MRI facilities that operate under the name Open MRI.
 
According to the fed., Imagimed submitted MRI claims for services performed with contrast dye without the direct supervision of a qualified physician.
“Since a potential adverse side effect of contrast dye is anaphylactic shock, federal regulations require that a physician supervise the administration of contrast dye when it is used for an MRI,” the press release notes.
 
But they weren’t content with the extra $100 they received per service, the DOJ claims. They also entered into illegal referral deals with doctors.
“In exchange for these referrals, Imagimed entered into sham on-call arrangements, provided pre-authorization services without charge and provided various gifts to certain referring physicians, in violation of the Stark Law and the Anti-Kickback Statute.”
 
Wolf, Greenan & Winter will pay $3.57 million to settle the case. Local radiologist and whistleblower Patrick Lynch, MD will receive $565,500.
The fed is silent on whether they will go after the referring doctors, but based on our reading of Medical Practice Compliance Alert, we suspect they too will be reaching for their checkbooks.