Hi Janice
The first thing to consider are the supervision requirements in your state. I don't know what they are, but you could check with the state agency that licenses PA's. Supervision requirements do vary significantly from state to state, but most if not all have some level of supervision required. It's possible that the hospital bylaws are following this, but of course the hospital can elect to be more stringent.
If your group is independent (i.e. not employeed by the hospital), how you bill is none of their business in my opinion. A physician certainly can't bill Medicare for a hospital procedure that he or she didn't personally perform. You MUST bill it in the name of the PA who did the actual work. If any pushback from the hospital on this front, I would ask them to produce a citation supporting their position.
I can't speak to whether supervision rules make sense from a clinical perspective, but as a non-clinical person, I would think it might vary by procedure. I'm sure there are some procedures where physician availability might be warranted.
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
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Original Message:
Sent: 07-30-2021 14:22
From: Janice Daniels
Subject: hospital bi-laws
Hello all, I have some questions on PAs. When a PA performs a procedure @ the hospital we feel the report should state that the PA performed the procedure and signed the report. Also these PAs and our Radiologist are NOT employed by the hospital. The hospital is telling us that per the hospital by-laws they need to state: either of these examples below: . Most of the PAs are trained to perform all of the procedures performed at the hospital. The hospital is also saying that if a PA is not trained and needs a doctor to be in the room to supervise the PA, we are to bill under the doctor even though the PA performed the procedure. can anyone please shed some light on this. the below sounds like something for residents and fellows. Not sure this is accurate for PAs. - supervised the procedure and was immediately available
- was present for the key elements of the procedure and immediately available
- supervised the procedure and was immediately available
Thank you,
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Janice Daniels CIRCC, CPC
Lead Coding Specialist
Rhode Island Medical Imaging
Warwick RI
(401) 432-2520
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