Hi Laurie
We do OP consults in the hospital setting, but we don't pay rent. The hospital registers the patients, provides the support staff and supplies, and charges a facility fee, and it's no different than a procedure done in the hospital. We bill POS 22 (could be 19 if off campus). Now that's a terrible deal for patients, because the facility fee is typically a few hundred dollars on top of the docs consult fee.
Alternatively, you could possibly lease space from the hospital or someone else, pay FMV, and provide the staff, systems, etc. to run the clinic, in which case you would bill POS 11. We also sublease space from another physician group for some of our IR consults, provide the staff, systems, etc., and bill POS 11.
The POS will drive reimbursement. POS 11, you will get the higher non-facility rate. POS 19 or 22 is the lower facility rate, which includes no allowance for clinical space, staff, supplies or equipment. Also, patients often have less out of pocket in POS 11.
The lawyers can weigh in more authoritatively, but I don't believe Stark is a significant consideration since no Designated Health Services are directly involved. If you're using space provided by a potential referral partner, you probably want to stay in an anti-kickback safe harbor, so FMV and a written agreement with at least a one year term would be important, among other things, if anything of value is changing hands.
Hope this helps.
Dave
David Smith, FACMPE | Executive Director | 913.444.9359
5800 Foxridge Dr. Ste 240 | Mission, KS 66202 | www.uickc.com
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