POS

[TammyL]

 I just started billing a group of therapist an the POS they were billing was 11 for office but they go to the patients home to do in home therapy.counseling shouldnt the POS be 12

[RichardP]

Yes.

If you think you want to do something about this, don't - until you know what the chart says.  The billing must match what is in the chart.  If the therapists are writing in the chart that they saw the patient in the office, when you know the patient was seen at home, you will need to consider whether you want them as a client.

[Merry]

Agree with Richard.  You need to find out why they are using 11 instead of 12

Merry

[PMRNC]

Hate to be the devils advocate as well but if you are billing the POS 11 when you know it's incorrect (appears you do know) you want to stop ASAP..
you become a knowing and willing participant once you are billing something you know is incorrect.

[RichardP]

We have a client who has set up a separate legal entity for home healthcare.  It has its own EIN and NPI Numbers.  Client hired a Nurse Practitioner to run the thing.  NP goes to the home and does her stuff, and we bill under the name and numbers of the home healthcare entity.  The patients' home addresses are listed as the place of service on this billing.

BUT - the NP draws blood and sends it back to the Office to be run through the doctor's Physician Office Lab (POL).  That works gets billed in the name of the doctor, with the doctor's numbers.

SO - is there a chance the stuff being billed as POS = 11 is actually work that was collected in the home - but the work being billed for was actually performed in the doctor's office?

[HeidiK]

Hi Richard,

It seems as if you have two separate issues to look into.  In regards to the blood draw, I believe the code you are using is 36415 and that should be billed with POS 12 under the separate home healthcare entity.  The tests themselves should be billed under the physicians office however, I'm not sure without more details if they are set up to actually "run" as a lab.  There are guidelines and rules if one facility accepts specimens from other facilities for processing.

The other issue regarding the NP performing services without direct physician supervision may need to be looked into also.  Rules and laws differ from state to state but Medicare is clear on their guidelines.  Sometimes it's hard to translate "CMS wording" but I found a Medical Economics article which was easy to understand.  Here is a quote and the link to the article is listed below also.  Check with your MAC for specifics and be sure whatever you are billing is properly documented.

"According to CMS, “Direct supervision in the office setting means the physician must be present in the office suite and immediately available and able to provide assistance and direction throughout the time the service is performed. Direct supervision does not mean that the physician must be present in the same room with his or her aide.”

Additionally, CMS states, “If auxiliary personnel perform services outside the office setting, e.g., in a patient’s home or an institution (other than a hospital or Skilled Nursing Facility,) their services are covered incident to a physician’s service only if there is direct personal supervision by the physician.”

Therefore, the only time when a NPP or auxiliary staff member can bill a service under a physician’s PIN is when a physician is in the office suite and directly available to help, if needed. The physician merely being available by phone does not constitute direct supervision."

http://medicaleconomics.modernmedicine.com/medical-economics/news/demystifying-medicares-incident-billing-nurse-practitioners-physician-assista?page=full

Hope this helps!

[RichardP]

Heidi:  I'm sorry I was confusing and not more clear.  Thanks for the effort.

I have no question.  We are billing properly and getting paid.

My comments were for the original poster - an example of work done in the home where some is billed with POS = 12 and some billed (properly) as POS = 11.  The blood draw itself is done in the home, so POS = 12.  The analysis of the blood is done in the POL, so POS = 11.  There may be something similar going on with the OP that might explain the POS=11 billing.  Just providing some alternative ways of looking at the situation rather than concluding without proof that the coding is incorrect.

[HeidiK]

No problem at all!  Without details it's hard to give the right answer so I try not to jump in too often! 

[PMRNC]

The original poster had said:

I just started billing a group of therapist an the POS they were billing was 11 for office but they go to the patients home to do in home therapy.counseling shouldnt the POS be 12

I'm thinking it's probably physical therapy or possibly psychotherapy?  Either case,  I still have to say "Houston, there is a problem".

[Michele]

I think it must be mental health.  We bill for therapists that go to patient's homes.  We use the POS 12 or 13 depending on what type of home they live in.

[paullad1]

Yes, it depends we need to confirm first whats in store in chart and then decide upon anything...