Some of our attorney friends will probably be able to weigh in more authoritatively, but I'm pretty sure the answer is that there is no compliance problem with having your PA do a consult in the hospital outpatient department. We certainly do them. Just be aware that the hospital will probably charge a facility fee, which can be considerable, and you should bill it with the hospital outpatient place of service, which means you will get paid the facility rate, which will usually be less than if it was your office.
Alternatively, you may be able to lease space from the hospital, which would allow you to bill with POS 11, and avoid the hospital facility charge to patients. Many hospitals have a shared clinic space available for this purpose. In that scenario, you would want to involve an attorney and ensure that the rent is fair market value to avoid anti-kickback issues.
Hope this helps.
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
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Original Message:
Sent: 06-17-2021 13:21
From: Holly Wallner
Subject: PA billing OP Consults in hospital settings
We have a PA that we want to do OP consults in the hospital on our potential /IR Patients. We have heard that this is a Stark violation since we do not have a dedicated office for consults nor do we pay the hospital "rent" for a space to do so.. Is this a Stark violation or any other violation? Can someone point me in the right direction to find this is in writing? Do others have PA's doing this and billing and getting reimbursed?
Help!
Thanks
Holly
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Holly Wallner
Practice Administrator
TRG, LLC
Portland, OR
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