Question on compliance- my wound care dr who is employee'd as third party for our wound care center but has his own surgery practice (not affiliated with us). He is referring patients to have him perform surgery (thru his practice) at the hospital and then come back to our wound care for care (not under global). I have involved our compliance office and MGT, but would this be a Stark law issue or am I off the wall, thank you
-
If this is your first visit, be sure to check out the FAQ & read the forum rules. To view all forums, post or create a new thread, you must be an AAPC Member. If you are a member and have already registered for member area and forum access, you can log in by clicking here. If you've forgotten your username or password use our password reminder tool. To start viewing messages, select the forum that you want to visit from the selection below..
Wiki Wound care referral to sx practice
- Thread starter mjstack
- Start date
-
- Tags
- self referral stark wound care
amyjph
True Blue
Are you stating the physician is seeing a patient in the office setting, deciding on surgery, and performing the surgery in a facility he has privileges at? Then, he may be seeing the patient for office or other services unrelated to a global surgical period?
I am a little confused by the question. This seems to be a multi-part question of employment, financial interest and a global surgical period question. I think you did the right thing in bringing it to your internal compliance department first to sort out. There could be a lot of background stuff that you may not know of going on. Especially when it comes to employed physicians, self referral, etc. It's always important not to jump to conclusions with things like this.
www.cms.gov
I am a little confused by the question. This seems to be a multi-part question of employment, financial interest and a global surgical period question. I think you did the right thing in bringing it to your internal compliance department first to sort out. There could be a lot of background stuff that you may not know of going on. Especially when it comes to employed physicians, self referral, etc. It's always important not to jump to conclusions with things like this.
Physician Self Referral | CMS
For Medicare FFS providers: Learn about the Stark Law and physician self referral regulations regarding designated health services.
Hello, thank you; The dr is seeing patients in hosp under his own tax id/Practice, performing surgery, having a global period and instead of seeing them at his surgical practice (another company all together) he sends them directly to wound care.
If Dr. A does surgery under TID#1 and bills for the entire surgical package, then same Dr. A sees the patient during the global period for services included as part of the global package under TID#2, it's still part of global care and should not be billed or paid. Complications without a return to the OR is part of the global surgical package.
Regarding TID#2 incurring expenses that TID#1 was paid for, that is something you will need to figure out internally. I suppose another option would be TID#1 bills for surgery with -54, then TID#2 bills for surgery with -55 (although I'm not 100% certain this is correct when it is the same physician).
Either way, the total payment will be the same.
Regarding TID#2 incurring expenses that TID#1 was paid for, that is something you will need to figure out internally. I suppose another option would be TID#1 bills for surgery with -54, then TID#2 bills for surgery with -55 (although I'm not 100% certain this is correct when it is the same physician).
Either way, the total payment will be the same.