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Hospital Owned Physicians office

  1. Default Hospital Owned Physicians office
    Medical Coding Books
    We are the billing office and we would like to get some direction on the following scenerio, specifically Nuclear Medicine in a Cardiology office. This is a new arrangement for the Cardiologist.

    1. The office is owned by the hospital.
    2. The equipment is owned by the hospital.
    3. The Doctor is an employed physician by the hospital
    4. The meds will be supplied by the hospital
    5. The staff in the office are employed by the hospital
    6. The Place of service will be office - 11.

    As an example, how would you bill a 78452? Modifiers etc...

    Thanks so much for your help!

  2. #2
    Location
    Columbia, MO
    Posts
    12,527
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    Your POS will be 22 not 11. As far as the modifiers go you will more than likely need a 26 on the pro fee and a TC for the facility fee. for most radiology tests. You need to check to see if this is a test that can be split this way. For office visits your physician will use the level met by the 95/97 guidelines, the facility will bill a facility fee using the E&M code that matches their facility guidelines.
    Last edited by mitchellde; 08-25-2011 at 10:32 AM.

    Debra A. Mitchell, MSPH, CPC-H

  3. #3
    Location
    Dover Seacoast New Hampshire
    Posts
    1,970
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    Deb...if the office is designated as an "office" and not a department of the hospital, why would POS be 22? Even if owned by the hospital, unless the practice is classified as provider-based, hospitals can own physician practices who do business in an office setting.

    Also, if there is a physician practice in a hospital building that is not classified as a department of the hospital, because the practice carries the expense of the overhead by renting the space from the hospital...why would this be called POS 22?

    Thoughts? and regulatory guidance? Thanks for the info.
    Pam Brooks, MHA, COC, PCS, CPC, AAPC Fellow
    Coding Manager
    Wentworth-Douglass Hospital
    Dover, NH 03820

    If you can dream it, you can do it. Walt Disney

  4. #4
    Location
    Columbia, MO
    Posts
    12,527
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    She did not say the physician would be renting the space and all the ancillary personnel are part of the hospital as well as all supplies. If the physicians are renting the space then yes POS 11. But the way the poster described the relationship I say 22, as there is no overhead for the physician. I agree just being located in the facility is not an automatic 22, but when the hospital is absorbing all of the overhead including personnel then it would have to be a 22.

    Debra A. Mitchell, MSPH, CPC-H

  5. Default
    Thank you for your replies. Would you have any idea where we can find any regulatory guidance for this situation?

  6. #6
    Location
    Dover Seacoast New Hampshire
    Posts
    1,970
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    Thanks, Deb. You're right, the OP didn't specify.
    Pam Brooks, MHA, COC, PCS, CPC, AAPC Fellow
    Coding Manager
    Wentworth-Douglass Hospital
    Dover, NH 03820

    If you can dream it, you can do it. Walt Disney

  7. Default
    If you bill a POS 22 is the hospital billing out their portion? If the hospital is not billing their portion of charges you should still use a POS 11. POS 22 splits charges into physician fee and facility fee. If you use POS 22 and your facility (hospital) is not billing the facility portion you will lose alot of money. For example, you bill a 99213 out at $70 using POS 22 your reimbursement will be $30.80 and the facility reimbursement would be $26.00 . (remainder is contractual adj) Same bill POS 11 your reimbursement is $56.80. Now, if your office uses POS 22 and the facility isn't billing their portion then you lose $26 a visit. Because the clinic is owned and operated by the hospital (hospital holds overhead and Doc is not renting space), and the Doc is employed by the hospital the hospital has the option of wether or not to bill the facility fee. That decision is what effects your POS. I hope that this helps. I just had this exact scenario with my family practice docs at the hospital that I work for. Good Luck.

  8. #8
    Location
    St. Joseph County, Indiana
    Posts
    101
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    FYI: The scenario initally described is a physician becoming a HOPD (Hospital Outpatient Department). This is typically used with cardiologists, pain management specialists and other providers who perform procedures in their office. As surgery center reimbursement as dropped and hospital reimbursement has grown, hospitals find it advantageous to stop owning surgery centers and work directly with physicians. Example: Medicare pays $275 for basic pain block in an ASC, but will pay $550 in a hospital outpatient dept. So hospital goes to busy physician and says we will buy/lease your office, equipment and staff; pay the physician a straight salary (not based on production), and bill the facility portion of the procedure as a HOPD....and the POS would be 22.

    Warning: Works great but not for the sloppy...The agreements must be very specific and carefully structured. If done incorrectly, you end up breaking a dozen federal laws.

    Brock Berta

  9. #9
    Location
    Columbia, MO
    Posts
    12,527
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    Quote Originally Posted by nnoyes View Post
    If you bill a POS 22 is the hospital billing out their portion? If the hospital is not billing their portion of charges you should still use a POS 11. POS 22 splits charges into physician fee and facility fee. If you use POS 22 and your facility (hospital) is not billing the facility portion you will lose alot of money. For example, you bill a 99213 out at $70 using POS 22 your reimbursement will be $30.80 and the facility reimbursement would be $26.00 . (remainder is contractual adj) Same bill POS 11 your reimbursement is $56.80. Now, if your office uses POS 22 and the facility isn't billing their portion then you lose $26 a visit. Because the clinic is owned and operated by the hospital (hospital holds overhead and Doc is not renting space), and the Doc is employed by the hospital the hospital has the option of wether or not to bill the facility fee. That decision is what effects your POS. I hope that this helps. I just had this exact scenario with my family practice docs at the hospital that I work for. Good Luck.
    Regardless of whether the facility is billing their portion correctly if the physician does not rent or lease the office and pay the staff himself then he cannot bill for that overhead with a POS 11 he must use the 22.

    Debra A. Mitchell, MSPH, CPC-H

  10. #10
    Default
    When you are billing for the physician are you billing with the hospitals tax id, or did the physician group retain their own tax id's for billing purposes?

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