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Global vs Split billing for imaging

arnoldmel

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Local Chapter Officer
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I am looking for supporting documentation on how to bill Medicare secondary when global code for imaging (74181) was paid by primary insurance. I am finding conflicting information.

The provider office owns the equipment and performed the diagnostic test in the office (TC) and per contractual agreement a radiologist off site read images (PC). The radiology group was paid via 1099 by the billing entity. The CMS anti-markup rule to separate TC and PC does not apply to commercial insurance, so claim billed globally to primary.

Does the CMS anti-markup rule apply to the claim? If not, then the claim can be billed globally to Medicare secondary, correct?

If yes, can the claim be split for Medicare secondary with modifiers TC and PC? If so, how should the CPT code and primary payment be split to file the claim? Please provide an example and supporting documentation.
 
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