General Surgery Coding Alert

Reader Questions:

Distinguish Facility vs. Non-Facility Fees

Question: Can you please explain whether we should use the facility global fee or the non-facility global fee if we’re billing for our surgeon’s service for a hospital outpatient?

Texas Subscriber

Answer: When your surgeon provides a service to a patient as a hospital outpatient, you should bill the facility global fee. You should not use the non-facility global fee, in this case.

Here’s why: Medicare pays more for visits that take place in a physician’s private office because you collect additional dollars to reflect the “cost of doing business” in your own practice. You don’t face those costs when practicing in a facility, so the pay is lower.

Reality: If you perform a service in the physician’s private office, use place of service (POS) code 11. For a hospital outpatient setting, use POS code 22 instead. The Medicare payer will adjust its fees based on which POS code you bill.

For instance: Code 49405 (Image-guided fluid collection drainage by catheter [e.g., abscess, hematoma, seroma, lymphocele, cyst]; visceral [e.g., kidney, liver, spleen, lung/mediastinum], percutaneous) has a large payment disparity based on the POS for the service. Medicare’s national payment amount is $889.58 for the non-facility POS, and $221.32 for the facility POS for 49405, based on conversion factor 35.7547.