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.
Who should attend?
- Sue Dill Calloway
Wayne J. Miller, Esq., is a founding partner of the Compliance Law Group, Los Angeles, a law firm focused on health care industry legal compliance for clients nationwide. Wayne has practiced healthcare business and regulatory law throughout his 30-year career. His firm represents a wide range of healthcare industry clients throughout the nation. He is a frequent speaker for The Coding Institute national teleconferences on healthcare reimbursement, transactional and regulatory...
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