Hi Linda
This question is probably best posed to healthcare legal counsel, but for what it's worth I will give you my take. I don't think there is a problem with your IR docs being paid by the vein clinic, assuming it is a physician practice. There would need to be some sort of independent contractor or employment agreement between the IR docs and the vein clinic, and the IR docs would have to complete an 855R for the vein clinic. Essentially your docs become part of the vein clinic practice for purposes of the work they do there.
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
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Original Message:
Sent: 04-26-2023 18:33
From: Linda CainBredl
Subject: CMS Guidelines for being paid under global billing
2nd request.
We have been approached to perform ablations for a vein clinic. They will bill globally and pay our surgeons for their IR services.
Is the rule still in place that we only receive payment for the professional portion of this service when the patient is covered by a government plan?
If so, where can I fine that rule in writing, so I can provide to my boss.
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Linda Bredl
Jacksonville, FL
412-303-2322]
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