Wiki 88305 split billing

SebNicole

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Hi All
I am trying to find articles to define Clinical Lab Billing/Coding requirements per Medicare.
We employ the both the Pathologist and the Technician.
Currently the PATHOLIGIST works PART TIME, so we were told we must bill the -26 for pathologist and pay pathologist exact amount medicare reimburses for -26.
Pathologist cannot benefit (be compensated) for any of the –TC Medicare reimbursement.
Therefore, we must split bill the -26 and –TC
Does this requirement go away if/when pathologist is employed FULL TIME?

Example: would be a 88305
Technician prepares silds and the Pathologist does the read.
Is it correct to bill to Medicare 88305-26 for part time patholigst read and –TC for Technical component.
 
The requirement to not pay a physician more than the Medicare reimbursement for a professional component is related to the anti-kickback statutes - I'm not sure that it necessarily would apply in this situation and/or whether or not the part-time or full-time employment status makes any difference. I've only read of this requirement in the context of a purchased service and not of an employment arrangement - employed physicians can usually be paid up to a 'fair market value' for their services regardless of Medicare rates. But either way, this is something that should be determined by an attorney who can review your physician's contract for compliance purposes. Please don't take a forum response or just someone's word on this because physician compensation arrangements are legally complex and really require a specialist to know the specific details and review the paperwork in order to ensure that they are compliant.

As for the TC/26 split, I don't believe that there would be an issue with billing the components separately vs. globally since the payment would be the same in either case (I've seen it done both ways by payers and providers), but you may wish to contact your specific payers to see if they have any policies requiring that it be billed in one way or another.
 
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