Incident-To, Locum Tenans, Reciprocal Billing
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This presentation will address the three rules that operate as exceptions to Medicare’s general rule requiring that services be reported under the name and NPI of the performing provider. Key components, documentation and reporting requirements associated with the Incident-To, Locum Tenens, and Reciprocal Billing rules will be identified. Additionally, using practical scenarios as examples, we will address some of the more common misconceptions of these rules that lead to non-compliance and disclosure liability. This discussion is intended to provide practical guidance on when or if practices should consider reporting services under these rules.
About The Author
Michael D Miscoe, Esq, CPC, CPCO, CPMA, CASCC, CCPC, CUC
Mr. Miscoe has a bachelors of science degree from the United States Military Academy, a juris doctorate degree from Concord Law School, is a Certified Professional Coder, Certified Ambulatory Surgical Coder, Certified Urology Coder, Certified Chiropractic Professional Coder, Certified Professional Compliance Officer, Certified Professional Medical Auditor, the President of Practice Masters, Inc., and the founding partner of Miscoe Health Law, LLC. He is the President Elect of the AAPC National Advisory Board, is a member of the AAPC Legal Advisory Board and is the Chair of the AAPC Ethics Committee. He is admitted to the practice of law in California as well as to the bar of the United States Supreme Court and the US District Courts in the Southern District of California and the Western District of Pennsylvania.
Mr. Miscoe has over twenty years of experience in healthcare coding and over sixteen years as a compliance expert, forensic coding expert and consultant. He has provided expert analysis and testimony on a wide range of coding and compliance issues in civil and criminal cases and his law practice concentrates exclusively on representation of healthcare providers in post-payment audits as well as with responding to investigations pertaining to HIPAA issues by the HHS Office of Civil Rights. He has an extensive national speaking background and has been published in numerous national publications on a variety of coding, compliance and health law topics.
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