A patient comes into the office with foot pain. The provider provider orders an x-ray which we perform. The provider then interprets the x-ray and diagnoses the patient with arthritis. We then sent the x-ray out to an outside radiology firm for an "over read" The radiology firm then invoices us for the readings.

Here is my problem....I discovered on an audit recently that our billing department has been billing out our x-rays with modifier TC attached to them for the technical component even though we perform the x-ray and provide the interpretation (i.e. the complete service). When I asked why we were doing this, I was told that this came about years ago through an outside audit.
We were billing the global component on everyone, because we have an agreement with a radiology group to bill us direct for the over reads.
The outside audit firm said that with Medicare you can ONLY bill global component IF the radiologist was under your roof reading the films.
The radiologists were not- so on Medicare patients we started billing only the technical component and we let the radiology group bill for the PC.

Can someone please clarify this for me? We should be reporting the global period with this correct? Is there any guidance from CMS someone can point me to? Thanks.