Wiki Billing for PA in MA

holsonf

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Massachusetts has a state regulation that PA's can't bill directly they must bill under a supervising provider. I'm new to billing in MA & was wondering how other practices handle this. If in MA how do you bill for your PA's that see patients by themselves? Does the Mass state regulation trump Federal & Commercial Insurance contracts?
 
Can you provide a citation for the MA state law that says this? My guess is that it has to do with supervision, not with billing.

In any case, there are a few grey areas but in general, states only have the authority to regulate businesses and insurance companies that operate wholly within the state - they have no authority to regulate how the Federal government conducts its business, and or over insurance companies outside the state, including those providing administrative services for self-funded plans. To the best of my knowledge, the state would also not have any say in how your provider does business with those entities in terms of billing, but if you can post the language of the law, that might be helpful in understand the scope of the regulation.
 
No experience billing in MA, and I have to say that does seem odd. From my experience the states usually dictate regarding scope of practice, not billing for NPPs. It seems they do allow the PA name to be on the claim form provided payment is issued to the employer/supervising physician and the supervising physician's name is also on the form. My guess is that this was created to help reinforce that the PA is working under the supervision of a physician and is not practicing independently or billing as a separate entity.
Per https://www.mass.gov/info-details/i...illing-for-a-physician-assistant's-services?- I love when they come up with a regulation, then advise you to seek legal counsel to interpret the regulation. :rolleyes:
What restrictions does the Board place on billing for a physician assistant's services?
Board regulations found at 263 CMR 5.06 state that, "A physician assistant may not bill separately for services rendered. The services of the Physician Assistant are the services of his or her supervising physician, and shall be billed as such."
The Board may consider a number of factors to determine whether a particular billing activity conforms to the requirements of 263 CMR 5.06. While the Board is aware that government programs such as Medicare and certain private payers in Massachusetts may require the use of a physician assistant's name or unique identification number on a billing form seeking reimbursement for services provided by the physician assistant, such use of a physician assistant's name or identification number, by itself, does not constitute "billing separately" in violation of Board regulations. It is the opinion of the Board that any determination as to whether a particular billing practice violates 263 CMR 5.06 must consider the totality of circumstances under which the billing takes place.
Notwithstanding the use of a physician assistant's name and/or identification number on a claim form, additional factors may indicate that a physician assistant is not "billing separately" in contravention of Board regulations. Such factors may include:
The identity of the supervising physician may be determined from the claim form.
The physician assistant has no responsibility for, or control over, the billing activities.
Funds are paid directly to the supervising physician or other employer, who subsequently provides payment to the physician assistant.
Please bear in mind that, pursuant to Board regulations, the physician, group of physicians or health care facility that employs a physician assistant is legally responsible for the acts and/or omissions of that physician assistant at all times. Also, the Board offers no opinion as to the billing requirements of Medicare or any other public or private payer. It would be advisable, therefore, for the physician assistant and the employer to seek legal counsel as to additional statutory and regulatory restrictions on billing practices.
 
Yes, just came across this same link myself. It sounds to me like what the law is intending is that the PA not bill as an independent entity - in other words that the PA not operate their own practice. But yes, always best to speak to an attorney familiar with the law and its case history before making any important decision about how to proceed.
 
Thank you both for your input. I agree before we make any internal policies an attorney should be consulted. I'm just curious to see how other practices in MA are handling their PA billing.
 
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