Independent ED Physician's Survival Guide to Medicare Reassignment Prohibitions
Published on Mon Feb 01, 1999
Editors Note: Although ECAs primary focus is on emergency coding and documentation, we also attempt to cover significant issues that effect emergency medicine billing and reimbursement. This article deals with establishing a billing mechanism for independent contractor emergency physicians that complies with the recent, new interpretation of Medicares reassignment of payment rules by the Health Care Financing Administration (HCFA).
Whether you are an independent emergency physician contractor working at three different emergency departments, an emergency medicine billing company providing services to several large emergency practice groups, or a hospital that handles billing for its ED, Medicares recent crackdown on reassignment of payment has hit you hard.
For years, independent physicians had been allowed to accept a flat salary or per-hour payment for services from their practice management company and, in turn, re-assign payment of their Medicare claims to that company.
Now, however, the HCFA has ruled these reassignment arrangements invalid and that the only reassignment of payments they will accept are those between employers and employees, from physicians to their medical groupif the health care facility is owned by that medical group; reassignment to a health care delivery system or HMO; and, reassignment by physicians assistants.
Emergency physicians who are independent contractors (ICs) or the companies that handle their billing now have three options, notes Edward R. Gaines, III, senior vice president of compliance and general counsel for Healthcare Business Resources, Inc. a large emergency medicine practice management company with contracts across the country.
These physicians can either become an employee of the management group or groups they currently contract with, form a limited partnership with other emergency physicians (this would make them a delivery system), or set up a banking account known as an electronic lockbox to receive their Medicare payments and then have them automatically sent to the group or company of their choice.
The last option, notes Gaines, is the only one that allows IC physicians to remain truly independent.
Many local emergency groups use independent contractors, and this is exactly how I would tell them to set up the billing, he says.
Emergency Groups Must Act Quickly
The bottom line, Gaines notes, is that emergency physicians and practice groups must decide which course to follow and decide it quickly.
In October, HCFA announced that it was instructing carriers to begin reviewing physicians with multiple reassignment arrangements. Any physicians found to be re-assigning payment to a ineligible company are now subject to a fraud investigation and loss of Medicare participation.
Physicians must file the form HCFA-855 with their Medicare carrier for each company that is eligible and will be accepting payment on their behalf. Or, they must submit a HCFA-855 to receive a provider number on their own and receive their reimbursement directly.
If physicians dont [...]
