Billing for Non-Physician Services: Know the Rules

Rules of Direct and Indirect Billing for Non-Physician Services and How They Apply In Particular Disciplines

Ongoing Medicare recovery efforts demonstrate that improper billing for non-physician services is a major audit issue. Both medical and facilities nowadays rely on all types of non-physician providers to provide health care services, from licensed physician extenders, to technicians, to unlicensed medical assistants. Some of these services can be billed as if a M.D. performed them, some can be billed directly and some are not billable at all.

The billing rules in this area are complex. Incident to rules dictate whether a non-physician service can be billed under a physician’s provider number. Visits to certain other licensed professionals can be billed in their name to Medicare at a lesser rate, if a number of minimum requirements are met. Still other services, like acupuncture or chiropractic, cannot be billed directly or indirectly. Even if the service itself is billable, the other requirements for payment can also trip up a provider. For example, if the proper level of supervision mandated for incident to billing is knowingly not performed by a physician, false claim and Stark law allegations could be asserted as well as a demand for recoupment.

In this session expert speaker Wayne J. Miller will discuss the basic rules of direct and indirect billing for non-physician services, and provide examples of how they apply in particular disciplines, such as physical therapy, mental health and complementary care. Wayne will discuss lessons learned from recent cases and also discuss the key additional requirements that often are overlooked, including physician supervision, documentation and plan of care obligations.

Session Highlights:

• When is incident to billing allowed and when it isn’t
• Are there different billing standards for offices vs. hospitals?
• Types of services that can never be billed to Medicare
• Sweating the details: complementary care, mental health services
• How to fix defective physical therapy billings
• Lessons from recent cases
• Reducing fraud and abuse, Stark law risk
• Key requirements that are overlooked: physician supervision, documentation and plan of care obligations

 Session Snapshot:

• Direct, indirect payment of non-MD care
• Incident-to Rules
• Employee Standards
• Location and Services
  • Hospitals
  • Incident-to service provided by FQHC employee
  • Traditional home care
  • Special applications
  • Mental health
  • Complementary disciplines
• Get paid directly?
• Incident-to Payment?
• Stark law fundamentals
• Anti-Kickback Law
• Fraud & Abuse issues
• Assessing your compliance
• Identifying and fixing problems

Who should attend?

• Hospitals
• Physicians
• Practice managers
• Medical groups
• Health care consultants
• Medical practice and facility executives

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