Wiki Ordering should count even when the test is billed - Need Feedback

[dhunterc]

Hi all!

I know this question keeps circulating but I only see where people comment that they heard or that someone told them that if you bill for a test that you cannot count the order as part of MDM. Can someone please point me to specific written guidance on this? AMA says the actual performance or interpretation of the test cannot be included if you are billing separately - which makes sense. But where is the credit for the MDM to actually order the test? If we don't bill the test in house, we get the MDM credit for ordering it, why should it be any different if we bill for it? The CPT for the test does not include any E/M component - what about the work it takes for the provider to decide which test should be order for the patient - should that not be given credit as part of MDM?

TIA!!

 

[thomas7331]

I agree with you - the guidance is clearly stating that they are talking about 'physician performance' and/or interpretation of a test or procedure which is separately billed. In other words, they are saying that if the physician is billing for interpretative work as a part of a procedure, then it would be 'double dipping' to bill that same work again as part of an E&M service. They are not talking about tests that the provider is ordering which the physician is not personally performing - whether sent out or done within the practice or facility. Just because something is done 'in house' does not mean it is personally performed by the physician.

Hopefully the AMA, CMS or payers will publish some clarification on this and other questions - these new rules which were intended to simplify things are actually creating significant confusion instead.

 

[dhunterc]

I agree with you - the guidance is clearly stating that they are talking about 'physician performance' and/or interpretation of a test or procedure which is separately billed. In other words, they are saying that if the physician is billing for interpretative work as a part of a procedure, then it would be 'double dipping' to bill that same work again as part of an E&M service. They are not talking about tests that the provider is ordering which the physician is not personally performing - whether sent out or done within the practice or facility. Just because something is done 'in house' does not mean it is personally performed by the physician.

Hopefully the AMA, CMS or payers will publish some clarification on this and other questions - these new rules which were intended to simplify things are actually creating significant confusion instead.

My thoughts exactly! Thank-you!