Medical Billing Forum

Billing => Billing => Topic started by: Laniesa on July 25, 2013, 03:38:27 PM

Title: Billing for Speech Therapy
Post by: Laniesa on July 25, 2013, 03:38:27 PM
I have a Speech Therapist with no office that does only home visits. She would like to bring on more licenced Speech therapists but would like to bill under her until the credentialing is complete. Is this legal as long as she reads the notes and signs off on the therapy?
Title: Re: Billing for Speech Therapy
Post by: Merry on July 26, 2013, 12:04:13 PM
Is she actually supervising the therapist or just using the credentialed numbers? I would say no. Is this a corporation and are the additional therapists employees or sub-contractors? If Medicare I can give you answers but not sure what the situation is here.
Title: Re: Billing for Speech Therapy
Post by: Laniesa on July 26, 2013, 01:44:30 PM
This is not a corporation and she would actually not be physically there but would read her notes and do follow up with the patient/parents. She does not see Medicare patients as her patients are all children. The additional therapists will be sub contractors.
Title: Re: Billing for Speech Therapy
Post by: RichardP on July 26, 2013, 05:57:15 PM
Here are a few points that will help you figure this out.

1.  A service provider is free to hire and pay anyone they want to, to assist them in providing their services.  Such services will be billed under the Type 2 NPI Number (who gets paid) of the one doing the hiring (in this case, your Therapist).  Some carriers, including Medicare, require that the Type 1 NPI Number (who did the work) of the person(s) hired be included when billing.

2.  A service provider is licensed to provide a specifically-defined range of services.  They are given a taxonomy number that defines this range of services.  With very few exceptions, the service provider may not perform and bill for procedures that are outside of those covered by their taxonomy code.  Insurance carriers can and do refuse to pay for such services.

3.  A collection of service providers may come together and form an organization that is a legal entity.  That legal entity must then obtain a Type 2 NPI Number (who gets paid).  All billing would be done in the name of the legal entity, using that legal entity's Type 2 NPI Number.  All payments would be made to the legal entity, and the legal entity would then pay its owners and employees according to a written payment schedule.  In this situation, some insurance carriers (including Medicare) require that the Type 1 NPI Number (who did the work) of the service provider who actually did the work be included when billing.

Laniesa - in your situation, your Therapist can hire whomever she wants, bill for their services under her Type 2 NPI Number, and pay the worker/therapists whatever she wants to - under these three conditions:  1.) the people hired must be helping your therapist provide the services that she provides; 2.) since she is billing under her NPI number, she must supervise those she hires.  There is a legal definition of "supervision" in this instance, and a health-care attorney can help you with that, and;  3.) the work done by the folks she hires must fall within the work covered by her taxonomy code.

Assuming that she is a speech therapist, and is hiring other speech therapists, she probably meets the criteria of my Point 3 (they are all doing work covered under her taxonomy code).  But she is likely to fall down on my Points 1 & 2 - in that the hirees must be assisting her in her work (seems like they won't be), and she needs to be physically available to her workers in order to be able to bill for their services under her NPI number.

We have several clients in Beverly Hills, CA who have hired PAs.  In checking out the supervision requirement, we learned that, as long as the hiring service provider is "in town" and available by phone, he is meeting the supervision requirement.  That criteria is a state law and is likely to be different wherever you are.  You need to consult someone who knows the law for your area re. the definition of "supervision".  But I don't see that you can overcome the requirement that the hirees be helping the hirer in carrying out the hirer's work.  When you have a collection of service providers, all working on their own stuff - the only way you can bill under one Type 2 NPI number is to form the legal entity and have the legal entity acquire its own Type 2 NPI Number.  And you've already said that there is not a legal entity in the picture here.

A health-care attorney who knows your local law can say whether there are any temporary alternatives available to you.

Title: Re: Billing for Speech Therapy
Post by: Laniesa on July 29, 2013, 11:43:35 AM
Thanks Richard you have been a great help!!