Krissy,
We are encountering this as well and here are some things to consider. The site/hospital could either use its current Tax ID or set up a new Tax ID for the professional fee billing. The site would bill Medicare Part A for claims processing and, if they set up a new Tax ID, this will require new payer contracts. The radiologists will need to reassign their benefits in either scenario.
Or the site/hospital may want to use the group's Tax ID - be careful here because this means the liability will fall to the group, which is a negative since you will likely have little to no control over how the site/hospital performs the billing and accounts receivable management. A bigger problem with this option, however, is unless all sites/hospitals adopt global billing, it means some of the group's billing might still be done by your biller (billing company or in-house). While more than one entity can submit a claim to Medicare, a Tax ID can only have one "pay to" address. And the biller will be billing under your tax ID for the remainder of the professional services that are not paid on a per RVU basis. Payments for both the biller's claims and the site's/hospital's billing will all go to one "pay to" address. This approach is difficult as model and sorting out the payments between the entities is a nightmare. You will likely also want to reconcile/verify the accuracy of what you are paid by each site/hospital. With respect to MIPS, the entity billing the claims is the one who is financially impacted by MIPS which would be the sites/hospitals who are billing globally and paying you on a per RVU basis. Unless there is something in the Professional Services Agreement that speaks to the site/hospital holding the physicians accountable for MIPS, then you are "off the hook."
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Barbara Rubel, MBA, FRBMA
Senior Vice President, Marketing & Client Services
MSN Healthcare Solutions
Past President, FRBMA & GRBMA
Past President RBMA
Green Cove Springs FL
(770) 823-3597 (M)
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Original Message:
Sent: 04-22-2024 13:31
From: Krissy Luke
Subject: Medicare Rule for wRVU based contracts
We are exploring a new contract where the entity plans to pay per wRVU instead of us billing for professional fees. Does anyone know that physicians must bill the professional component for Medicare?
Thank you!
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Krissy Luke MHA
Executive Director
Radiology Specialists of the Northwest, PC
Portland OR
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