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Wiki Oncologist not employed with hospital

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cpccoder2008

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I do the billing for only the physician's at a hospital. The nurse's who are administering chemotherapy are employed by the hospital but are being observed by my physician. The drugs and medicine are supplied by the hospital. I can only charge for the administration and supervision of my physician. My question is can i bill for chemo if it is admin from a nurse who is NOT employed by us ???
 
According to other forums i can't bill it. Only the hospital who is administering the drugs and owns the drugs, i am so confused. But regardless of who is right/wrong i still need something in writing before. If anyone can please help me ??
 
I'm confused with you.

I don't do much with chemo anymore but the hospital is billing incident to your physician, correct?

I don't see why you wouldn't bill for his part of the administration. Obviously you wouldn't bill for the drugs since he did not buy them, that would be strictly hospital based.

When you bill physician services with place of service 21 or 22 you are not being reimbursed for nursing staff, only physician time. The hospital would bill a facility fee to cover their staff.

Hopefully I'm understanding the question.

Laura, CPC, CEMC
 
There is no code for the obsevation of the administration and regs state you may not bill a physician visit level on the same day as chemo admin unless it is for a purpose other than the admin of the chemo. The nurses are employed by the facility, the facility supplies and mixes the drugs, the facility charges the chemo admin codes. The physician does n ot get to charge. Honestly he is not there observing this patient the entire time I would guess. At the cancer center the physician would swing thru and visit with each patient and spent maybe an hou total seeing all of their patient's that is all not billiable. If the patient is evaluated on the day of chemo but is deemed to be unable to recieve the treatment that day then the physician may bill a visit level.
 
I don't think it is fair but according to everything i am hearing it is accurate. The physician cannot bill the chemo codes because the nurses are administering the drugs therefore they bill the codes. To be honest with you he does spend time with each patient observing and monitering them. He comes from private practise where he was able to do this so he is trying it with our hospital to. But i don't know how much longer he will do this when he finds out we aren't billing the chemo codes and he can't bill an office visit either. I have recieved alot of feed back regarding this issue but can't find anything in black and white to back me up. We were assuming that we couldn't bill which is why i have been holding charges but now we just need some proof to show for why we aren't.

Thanks everyone
 
mitchellde said:
There is no code for the obsevation of the administration and regs state you may not bill a physician visit level on the same day as chemo admin unless it is for a purpose other than the admin of the chemo. The nurses are employed by the facility, the facility supplies and mixes the drugs, the facility charges the chemo admin codes. The physician does n ot get to charge. Honestly he is not there observing this patient the entire time I would guess. At the cancer center the physician would swing thru and visit with each patient and spent maybe an hou total seeing all of their patient's that is all not billiable. If the patient is evaluated on the day of chemo but is deemed to be unable to recieve the treatment that day then the physician may bill a visit level.
Click to expand...

I have another question. We are suppose to be hiring a nurse who will be employed under us, meaning the physician. Can we bill for chemo that she is administering and the facility bills for the drugs ?? Since he will be our nurse we should be able to bill right ?
 
I would say yes but you need to check with the facility to see if they will allow this. I know the one I worked at would not allow a nurse that was not their employee to work in their facility it comes under their liability. Your physician would have to be with her 100% of the time, never leaving for a minute. There just is no way around this. The only way to charge an office encounter on the same day is to meet the requirements of the 25 modifier and show that the visit was for purposes beyound that necessary to administer the chemo, this does not include going over the patient's bloodwork and check hydration status as that is a part of chemo admin. When your physician sees the patient for evaluation and orders the chemo as a plan, it should be included in you MDM that the chemo would have this evaluation in order to maybe obtain higher levels at that time.
 
20.5.7 – Injection Services
(Rev. 397, Issued: 12-16-04, Effective: 01-01-05, Implementation: 01-03-05)
Where the sole purpose of an office visit was for the patient to receive an injection, payment may be made only for the injection service (if it is covered). Conversely, injection services (codes 90782, 90783, 90784, 90788, and 90799) included in the Medicare Physician Fee Schedule (MPFS) are not paid for separately, if the physician is paid for any other physician fee schedule service furnished at the same time. Pay separately for those injection services only if no other physician fee schedule service is being paid. However, pay separately for cancer chemotherapy injections (CPT codes 96400-96549) in addition to the visit furnished on the same day. In either case, the drug is separately payable. All injection claims must include the specific name of the drug and dosage. Identification of the drug enables you to pay for the services.

http://www.cms.hhs.gov/manuals/downloads/clm104c17.pdf

Maybe I am off base on this, but I have a really hard time with the physician being responsible for these patients but not allowed to bill for anything.

I haven't billed for chemo in a few years and we had our own center, it wasn't hospital based.

Just trying to help,

Laura, CPC, CEMC
 
I agree Laura which is why i have been holding off on telling him that i can't bill any of his services. I understand that the hospital should be billing the administration codes because the nurses are employed by them, but if we hire nurses then we should be billing those services and the hospital bill for the drugs. What i don't understand if what can i bill for in the mean time ?? My physician is on the floor in and out the chemo room's through out the day. He is monitering the patient's as well as supervising the nurses. He is not there the entire time like the nurses but he is there i would say at least half of the time. I have read that you cannot bill an E/M visit the same day as chemo unless of a complication or something then you use a -25 but someone told me i could bill on Observation E/M as long as the physician document's.

Also i have another thread posted. In the CPT book the section before the chemo codes there is a statement that states " Codes 96401-96402,96409-96425 etc. are not intended to be reported by the physician in the facility setting" What is defined as a facility setting ? We bill POS 22 but our clinic is located in the hospital because of the equipment used. Does this mean a physician can't bill these services at all ?? That doesn't sound right with me because how are they billing in private practise ?
 
"In private practice".. If you are meaning in the physician office then it would not be in a facility setting and the physician would use the chemo admin codes to reflect the resources consumed in his office. If you are billing place of service 22 then that is facility outpatient and that is a facility setting. I assume the facility has an outpatient infusion unit where these services take place, that is the facility setting. If you run a clinic operation in the facility and use facility provided resources then that is a facility setting. I understand that your physician runs in and out of the rooms on the infusion unit but there is no way he can charge each individual patient's payer for activity he is providing for a group of patients all at one time, which is essentially what is happening. He is probably seeing other patients in the clinic at the same time that he does charge for. There is no observation code that can be used and charged for this activity. The chemo admin codes are for the administration of the chemo and that is the nurses which are under the authority and supervision of the hospital. If you hire your own nurses that if fine then you will need to have them administer the chem in YOUR office setting POS 11, and then you can charge the administration charges, However, I doubt the hospital will supply the drugs for you as there will be no way for them to charge, they are not a dispensing entity and cannot charge for the dispensing of the drugs for others to use. If you want the reimbursement then you will have to hire chemotherapy trained nurses and order the drugs and administer this within your own office setting. I know physician that have taken this on and they like it, but it can be quite the expense.
 
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