Neurology & Pain Management Coding Alert

Avoid OIG Scrutiny:

Master Work Plan Problem Areas

Because the U.S. Office of Inspector General (OIG) intends to scrutinize consolidated billing in 2003, neurology practices must submit technical component claims (modifier -TC) directly to skilled nursing facilities (SNFs) not to Medicare for their SNF patients. The Balanced Budget Act of 1997 requires SNFs to consolidate billing for Medicare Part A residents, meaning that physicians who perform in-office procedures such as electromyograms (EMGs, 95860-95872) on SNF patients must bill the technical component of the service to the SNF. Forge Relationships With SNFs When an SNF calls your practice to schedule a procedure, the receptionist should indicate on the patient's fee ticket that he or she resides in an SNF. "When the fee ticket gets to the coder, they should create another, separate fee ticket," recommends Deb Hudson, CCS-P, coder at the Mason City Clinic, a 30-physician multispecialty practice in Iowa. "The fee ticket for professional services will go to the patient's Medicare Part B carrier, and the other fee ticket, for technical services, is billed to the SNF with modifier -TC [Technical component]." Hudson suggests setting up separate accounts for the various SNFs in your area so coders can send the information to the appropriate party at the nursing facility. Remember that you may bill a procedure's technical component only if your practice owns the equipment (x-ray, EMG, etc.) and pays the salaries of the personnel taking the films: The -TC modifier's fee includes those technical costs. Consolidated billing rules also apply to physical, occupational and speech therapy services furnished to SNF residents covered under a Part B stay. These therapies are the only Part B services included in SNF consolidated-billing regulations. You can still bill Medicare directly for SNF patients' E/M visits, however. The 'Ins and Outs'of Incident-To Medicare defines incident-to services as those provided by a nonphysician practitioner (NPP) and which are an integral part of the physician's personal professional services in the course of a diagnosis or treatment of an injury or illness, says Ron Nelson, PA-C, reimbursement policy analyst, president of Health Services Associates Inc., a family practice in Fremont, Mich., and past president of the American Academy of Physician Assistants. Report services provided incident-to using the appropriate CPT codes under the supervising physician's personal identification number (PIN). Payers should reimburse such services at the full fee schedule amount. Note: Incident-to services are distinct from those provided by an NPP using his or her own PIN, which follow different guidelines and are generally reimbursed at 85 percent of the Physician Fee Schedule rate. There are four main guidelines for billing incident-to, as outlined in section 2050 of the Medicare Carriers Manual (MCM). The NPP providing incident-to services need not be licensed under state law as [...]
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