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billing Medicare for physician services to hospice patients

sgass0

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Location
Laguna Niguel, CA
Hello,
I am looking for assistance with billing Medicare for physician services provided to hospice patients.

Specifically, I am wondering: 1) If a physician serves as medical director of a hospice agency under a contractual employment agreement, can that same physician bill Medicare B for independent attending physician services when he is named as the attending physician? 2) If a physician serves as medical director of the hospice agency under a contractual employment agreement, can that same physician's NP or PA bill Medicare B for independent attending physician services on behalf of the physician, who is named as the attending physician? and 3) Can a physician's NP or PA bill Medicare B for independent attending physician services on behalf of the physician, who is named as the attending physician, when the physician has no contractual employment relationship whatsoever with the hospice agency?

Chapter 11 of the Medicare Claims Processing Manual seems to say no to all three, but I am being advised otherwise.

Thank you
 
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