The OIG has issued two new reports that reveal the plans of CMS to conduct more unannounced site visits of independent diagnostic testing facilities (IDTFs) nationally.  The reports describe findings that in Miami and Los Angeles, IDTFs did not comply with Medicare standards requiring IDTFs to: (1) maintain a physical facility at the location on file with CMS, and (2) be open during business hours. IDTFs that do not comply with Medicare standards are subject to a variety of administrative actions, including revocation of their Medicare billing privileges.  In Miami, unannounced OIG site visits in May 2010 found that 27 of 92 area IDTFs failed to comply with the selected Medicare standards. The OIG’s inspections in Miami came at the same time that CMS was conducting site visits to all IDTFs in South Florida as part of the “South Florida High Risk Enrollment Project.” As a result of its special enrollment project and routine oversight, CMS took action against 23 of the 27 noncompliant IDTFs that the OIG identified, but three IDTFs still received Medicare payments while CMS was revoking their billing privileges. Separately, OIG site visits in May and June of 2010 found that 46 of 132 Los Angeles-area IDTFs were noncompliant with the two Medicare standards. In both reports, the OIG recommended that CMS periodically conduct unannounced site visits to IDTFs and take action against noncompliant IDTFs identified by the OIG. CMS concurred with these recommendations. In particular, CMS states that it anticipates increasing the frequency of unannounced site visits to IDTFs, as authorized by its final February 2, 2011 provider/supplier screening rule that classifies IDTFs as “moderate risk” providers subject to unannounced site visits.  According to CMS’s response to the OIG, CMS is soliciting a contractor to conduct site verifications on a national scale, and it plans to begin systematically screening enrollment data with public source data to identify changes that could warrant further investigation. CMS also announced that it is exploring options to use payment suspensions in conjunction with revocation actions for providers and suppliers that are found to be nonoperational. The OIG also recommended that CMS impose a moratorium on the enrollment of IDTFs in the Los Angeles area (the OIG did not recommend a moratorium in Miami due to the existing CMS special enrollment project). CMS disagreed with the enrollment moratorium recommendation at this time, but CMS stated that it would consider the recommendation as it develops criteria for potential enrollment moratoria for a number of locations, including Los Angeles. CMS would be required to publish a Federal Register notice if it were to announce any such moratorium.