Provider Based Billing and Nurse visits

Dialmam

Networker
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33
Location
St Petersburg, FL
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I code for professional charges for a health system that utilizes a provider based billing model. The organization has undergone a restructure and now many RNs that used to be employed by the physician practices are now employed by the facility. We were billing nurse visits and/or injection administrations when performed by the physician practice nurse. Now that the nurse in employed by the facility, are we still able to bill the nurse visit? Provider based billing rules are tricky, and so far the answer I think I found is no, because they are not "from the same employer/entity". Has anyone run into this issue? also to complicate the rules, the physician practice may lease blocks of RN time. How does that factor into professional service billing nurse visits?

here are my resources
www.cms.hhs.gov/transmittals/downloads/R1776B3.pdf
https://www.law.cornell.edu/cfr/text/42/413.65

Thank you
 

thomas7331

True Blue
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3,146
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You're correct in that you cannot bill the nurse visits/injections as professional charges under a provider based arrangement. These are 'incident to' services in the physician office setting and if your practice is now facility based, no 'incident to' services can be billed on your Part B professional claims. That said, you can and should still bill for these services - the difference is that the charges will be submitted on the UB form as a line item on the facility claim submitted to the Part A carrier. Only services that are personally performed by the providers (physicians and NPPs) will be billed on the 1500 forms under their own IDs. The facility is responsible for submitting all ancillary services.

I'm a little puzzled by your arrangement of 'leasing' RN services - if the physicians and RNs are all employees of the facility, there shouldn't be a need to lease between employees of the same organization?

Provider based billing is pretty confusing, you're right. I went through a similar transition a couple years ago - if I can be of any help, please feel free to contact me.
 
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