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Wiki Radiologist only documents face to face time

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Weberr

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One of the radiologists employed by my company expects us to bill E/M charges based solely on the amount of face-to-face time he spends with a patient. He refuses to document any of the other elements required to support the level he expects. He provides the code he wants billed and documents the time. Has anyone else encountered this? We would like to have an idea of who carries the liability if we ask our billing company to code this way. Is it the billing company's, the radiology group's, or the individual radiologist's? Thanks.
 
Time alone does not support billing and E&M code, he would also at the very least need to document that more than 50% of the time was spent counseling and/or coordinating care and document the nature of the counseling. The financial liable party, if audited, would be to the payee (probably the radiology group) for any identified overpayments due to incorrect billing, but anyone who knowingly participated in the submission of false claims could potentially be subject to criminal liability under the false claims act, if applicable.
 
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