I believe the answer actually depends on the nature of the relationship the billing entity has with the physician who performed the service . . .
As Tom pointed out, claims for "
reassigned" services
must be billed to the B/MAC with jurisdiction based upon the geographic are where the services were rendered (ref MCPM Chapter 10, Section 10.1.1.3).
However, the rules are different when submitting claims for "diagnostic tests subject to the anti-markup payment limitations" . . .. and I suspect that's where there may be confusion. We're not allowed to say "purchased services" anymore, but that's typically what these are - technically, the correct Medicare language involves physicians who do not "share a practice" with the billing provider. In these cases, the billing entity "must submit all claims for anti-markup tests to their local B/MAC" and the "B/MACs must accept and process claims for services subject to the anti-markup payment limitation when billed by suppliers enrolled in the B/MAC's jurisdiction, regardless of the location where the services were furnished." The billing entity must "report the name, address, and NPI of the performing physician or supplier on all anti-markup . . . claims, even if the performing physician or supplier is enrolled in a different contractor's jurisdiction." Ref. MCPM Chapter 1, Section 10.1.1.2.
For more on the diagnostic tests subject to the Anti-Markup rule, see also:
30.2.9 - Payment to Physician or Other Supplier for Diagnostic Tests Subject to the Anti-Markup Payment Limitation
30.3.7 - Billing for Diagnostic Tests (Other Than Clinical Diagnostic Laboratory Tests) Subject to the Anti-Markup Payment Limitation
------------------------------
John Outlaw
Vice President, Compliance
Strategic Radiology
Florence SC
------------------------------
Original Message:
Sent: 03-04-2020 17:04
From: Thomas Greeson
Subject: TELERADIOLOGY CREDENTIALING
At least for reassigned claims, Medicare Claims Processing Manual (PUB. 100-04), Chapter 1, § 10.1.1.3 still appears to be the guidance from CMS.
"Though a supplier or provider may reassign payment for his services to another entity, suppliers are still required to bill the correct B/MAC for reassigned services when they are paid under the MPFS. The billing entity must submit claims to the B/MAC that has jurisdiction over the geographic area where the services were rendered. Suppliers and providers must also meet current enrollment criteria stated in chapter 10 of the Program Integrity Manual in order to be able to bill for reassigned services."
Tom
Thomas W. Greeson
703.641.4242
tgreeson@reedsmith.com
Reed Smith LLP
7900 Tysons One Place, Suite 500
McLean, VA 22102
703.641.4200
703.641-4340 Fax
www.ThomasGreeson.com
Follow us on Twitter @ReedSmithHealth
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Original Message------
We were also told that information for a physician we had in Tennessee.
Thank you,
Carol Hamilton, MBA, FRBMA, FACMPE, SHRM-SCP
Chief Administrative Officer
West County Radiological Group, Inc.
11475 Olde Cabin Road, Suite 200
St. Louis, MO 63141
P: 314-991-8201
F: 314-991-8282
C: 314-307-2518
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