Thank you Brandi,
Each hospital is billing for their own services (technical component). But both groups are independent and not employed by the hospital. They bill for their own services (professional component). I believe most of the rules posted are for the hospital and physician relationship; and a physician to physician relationship. Am I wrong?
I'm not sure I understand your question, then - how does your doctor fit into all of this? It sounds as though the groups (which I understood to be from different hospitals), both perform their own labs, and your physician performs the interpretation for both groups. If that's correct, then your physician should be billing for the professional component for the services, because that's what he's rendering. How he bills the services, depends on a couple of factors:
1. Is he billing as an independent physician, with his own tax ID and billing NPI, or is he affiliated with the groups (eg, shares their tax ID & billing NPI)? If he's his own entity, then he would report services under his own info. If he's affiliated with the groups, you'd use the billing info corresponding with the group who he is working for, with each encounter. So, if he's interpreting charges for Group A, use Group A's TIN & billing NPI; if it's Group B's patient, then use Group B's info...unless he's not associated with either group, and is considered an individual practitioner - in which case you will always use his TIN and billing NPI, regardless of which group he's performing services for)
2. Are the groups billing for the whole procedure (both Technical and professional components), and reimbursing the provider for his services? (Also known as: "Pass-through billing")? If that's the case, then you shouldn't bill payers at all; you'd requisition the groups, for payment. (*Also worth noting: many payers explicitly prohibit the practice of pass-through billing, and require all providers to be individually contracted with their network; it's very likely that the hospital groups are violating their payer contracts, if they bill this way.)
The info I provided earlier, pertains to the provider's relationship with the hospital(s)/groups. It may or may not be relevant to your situation, but it's worth considering, anyways (particularly if your physician's practice is located within a facility owned by one of the hospitals) - I only brought it up because, unless the arrangement between the 2 hospitals, to split your physician's salary, fits into a STARK exception and/or AKS safe harbor, they may be at risk of violating one (or both) of those laws (which both carry steep penalties).
It's probably not your job to assess the legality of your physician's relationship with the 2 groups - that's normally a compliance/legal department function...but, the way that you bill services on behalf of your provider, should be spelled out in his contracts, so you'll have to address this question with that department, anyways.
If you discover along the way, that
there is no written contract with the groups, you'd be doing your doctor a favor to pass that info along - it's better to be safe than sorry. Hope that helps!