Several studies provide evidence and show overutilization of services and increased costs under the in-office ancillary services (IOAS) exception loophole to the Stark self-referral law. The exception has fostered over-ordering of anatomic pathology (AP) services by self-referring physicians to maximize profits. The IOAS exception was intended to afford patient convenience yet AP services are rarely ever done at the time of an office visit.
We have long advocated for closing the loophole and passing other laws that protect your ability to provide high-quality services in a fair competitive environment, by requiring direct billing of pathology services, or prohibiting markups of services.
More Information on Self-Referral
We have developed comprehensive resources to help CAP members, patients, physicians, and policymakers understand self-referral and its implications.
- Self-referral Statement to Congress (PDF, 105 KB)
- Self-referral (PDF, 86 KB)
- Frequently Asked Questions (PDF, 156 KB)
- Myth vs Fact (PDF, 113 KB)
- GAO Reports Estimates Physicians Who Self-refer Anatomic Pathology Cost Medicare Millions (July 15, 2013)
The following articles from various professional journals provide research studies on self-referral. These articles highlight the growing evidence of abuse of the self-referral arrangements and the need to protect patients by closing this loophole.
- Action Needed to Address Higher Use of Anatomic Pathology Services by Providers Who Self-refer (June 2013)
- Linkages Between Utilization of Prostate Surgical Pathology Services and Physician Self-referral (2012)
- Stark Law Exceptions (PDF, 30 KB)
- Centers For Medicare And Medicaid Services Physician Self-referral Website