If the PA sublets the office then this is his own practice. He is in a collaborative agrement with the physician as required under the state law, which states the physician must be reachable by fax or pager, or phone with in a certain time or distance. So he must bill this as his own practive so he must bill under his own NPI and not under another physician as the supervising, because a physician cannot supervise someone who has their own practice.
This does not violate the anti kick back unless they are referring patients to each other with the patients being given the choice of providers.
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