Is there written documentation that states we should follow our intermediaries rules over CMS rules? Not that they are different...but they are being interpreted that way.

I've written both CMS and my FI, and am awaiting response. Having an issue with the way they both describe a new patient.

My FI (WPS) states they determine whether physicians (same specialty) are of the same group by tax ID. So per their definition, location is not a factor.

A patient seen at our Main Street location, can transfer to the Elm street location, and even though he is new to the doctor at the Elm Street Clinic, he is still considered established.(since all our clinics bill under same tax id)

I agree completely, but have someone (above me) arguing that if they transfer, they are new. I need some sort of written reference please!

Thank you.