Practice Management

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  • 1.  Billing and documentation of preliminary read of CT scans

    Posted 03-15-2021 09:40
    Hello,  We are a Radiation Oncologist practice and have our own CT machine in an office setting.  We have a new doctor to our practice who is not a certified radiologist and does not read.  He will be doing a preliminary read of the scans and we will send the images to an outside radiologist group for a final report.  With our new doctor doing the preliminary read, can we still bill global, and what kind of documentation should be stated by our new doctor?  

    Thank you,
    Ginger Hooper

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    Ginger Hooper
    Billing Supervisor
    Dattoli Cancer Center
    Sarasota FL
    (941) 955-8088
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  • 2.  RE: Billing and documentation of preliminary read of CT scans

    Posted 03-15-2021 09:55

    A preliminary interpretation does not support the billing of a professional component service. The professional component must be billed to reflect the work of the interpreting radiologist. Whether you can bill globally (to include the final interpretation) depends on whether the interpreting physician is located in the same Medicare payment locality as the technical component location.

     

    Also if the services are ordered/referred my members of your group practice who are owners of the practice, the billing of the PC must meet the requirements of the Stark physician services exception. Also in that circumstance, the potential that the interpretation can be considered an anti-markup test must be reviewed as well.

     

    Thomas W. Greeson

    703.517.0495 (cell)

    tgreeson@reedsmith.com

    Pronouns: He/Him/His

     

    Reed Smith LLP

    7900 Tysons One Place

    Suite 500

    McLean, Virginia 22102-5979

    Office Telephone: 703 641 4242

    Facsimile:   703 641 4340

     

     

     






  • 3.  RE: Billing and documentation of preliminary read of CT scans

    Posted 03-15-2021 10:06
    Hi Ginger

    I don't think the form or content of the preliminary read will matter, since you won't be billing for it.

    With respect to Medicare, unless the reading radiologist meets the Medicare criteria for "sharing a practice", which sounds unlikely, you will not be able to bill globally, per se.  You can bill the professional and technical components separately, but you will have to bill the professional component under the anti-markup rules (see https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM6733.pdf).  Note that you will have to report the address where the reading radiologist sits as the service location in Box 32, and if it's different from your address enroll those addresses with Medicare.  If the address is in a different MAC jurisdiction, you will have to enroll and file the claims there.

    With respect to Commercial insurance or Medicaid, check your contracts and payor policies.  Most won't have a problem with global billing, but there may be some that prohibit billing for services purchased from another physician group.

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    David Smith FACMPE
    Executive Director
    United Imaging Consultants
    Mission KS
    (785) 393-8387
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