Not maintaining a PACS system. Involves peer review of cases, and reading xrays. Very gray area. One similar teleradiologist was audited and passed, due to the gray areas. A teleradiologist is somewhat a unique type of physician. The big difference with other physicians is no office, no JCAHO inspection's,, not subject to medical practice state mandates and inspections, no direct billing, etc. It looks like this is at the whim of any particular auditor. The IRS eliminated the "direct contact with a patient" clause, but still did not clear this up entirely. Also as per the IRS Code 62 defination of HealthCare, none of the definition parameters apply in this situation.
