Practice Management

Hello All

I am looking for help about billing for Registered RAs.

The thing I remember about RA is that they could not get an NPI and could not bill under there name.

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Jim,

As I recall they can get an NPI number but they still cannot bill for their services. However, last year the supervision rules changed on certain procedures to allow them to perform services under direct supervision and the radiologist can then interpret and bill.

Hi Jim,

CMS' changes in the supervision rules (reducing the level of required supervision from personal to direct) apply to diagnostic imaging tests (defined as the 70,000 series CPT codes).  These changes do not apply to "procedures" (defined as the 10,000 – 69,999 CPT codes).  

In the hospital setting:

• RA services are paid under the hospital's technical component payment
• Physician is paid for supervision & interpretation of diagnostic imaging tests, provided diagnostic supervision rules are met
  • Diagnostic supervision rules do not apply to procedures
• "Incident to" rules do not apply in the hospital setting

In a free-standing center:

Diagnostic Imaging Tests (70,000 series CPT codes):

• If RA is employed by the radiologist & diagnostic supervision rules have been met, physician may bill globally
  • Example: Barium swallow (a diagnostic test) performed by the RA under direct supervision
  • Technical physician supervision has been met

Procedures (10,000-69,999 series codes):

• If RA is employed by the radiologist AND physician is "hands on" OR if incident to rules apply, then radiologist may bill
  • Example: Radiologist does a consult for a vascular procedure, an attending physician relationship has been established, & the radiologist is on the premises
    • RA may perform the procedure & the radiologist may bill for it

The challenge most Radiologists have with the "incident to" rules is they do not typically have continuing, active participation in and management of the patient's course of treatment.

• The following requirements must be met before a Non Physician Practitioner (NPP) may bill under "incident to" provisions:
  • The NPP must be an employee of the physician
  • The initial visit (for that condition) must be performed by the physician
    • This means there must be a direct, personal, professional service furnished by the physician to initiate the course of treatment of which the services being performed by the NPP are an incidental part
    • This does not mean that on each occasion of an incidental service performed by an NPP, the patient must also see the physician
  • There must be personal supervision by the physician as an integral part of the physician's personal in-office service
    • The physician must be physically present in the same office suite and be immediately available to render assistance if that becomes necessary
  • The physician has an active part in the ongoing care of the patient
    • Subsequent services by the physician must be of a frequency that reflects his/her continuing active participation in, & management of, the course of the treatment

RRAs & RPAs are neither recognized nor enrolled in the Medicare program and historically, commercial payers have followed Medicare guidelines.

I hope this helps!