Medical Billing Forum

General Category => General Questions => Topic started by: Lindaabs on December 08, 2015, 11:01:15 AM

Title: Primary Care
Post by: Lindaabs on December 08, 2015, 11:01:15 AM
I have client located in Florida that wants to open a PCP in the same office where there is an existing Urgent Care Center.  His thought is that he would start by provide primary care for Medicare, Medicaid HMO’s and non-insured patients during normal business hours, and utilize the Urgent Care side for all sick visits and extended hours care, while being able to provide referrals for insurance.

Can the same address be used for both and would Medicare then pay as a PCP for annual physicals or routine care?  Is anyone else doing this and, aside from obtaining a new NPI#, what obstacles do you foresee down the road? 


Linda Runyan, CPC
Accurate Billing Solutions, LLC
Title: Re: Primary Care
Post by: RichardP on December 08, 2015, 01:15:52 PM
We have a situation where multiple providers (billing entities) are operating out of the same street address and Suite number.  We are in California.  I cannot speak for other states.

Each provider is a billing entity.  So each provider has given all relevant Insurance Carriers their Employer ID Number and their Type 1 and Type 2 NPI Numbers (if they have both).  That is the information the Insurance Carriers need to distinguish among billing entities.  It does not matter that the street address and Suite number is the same for all.

Linda - I am assuming that the Urgent Care Center to which you refer is a billing entity.  If that is the case, the Urgent Care Center would bill for all services they render to any patients referred to them and seen by them.  Federal law (and I presume your State law) prohibits the referring physician from receiving any kind of compensation for referring patients to the Urgent Care Center.

There is a situation where your client could have his own private practice and be an employee of the Urgent Care Center.  So he could theoretically get paid as an employee of the Urgent Care Center for seeing patients he referred to them from his own private practice.  If your client wants to consider this scenario, I would strongly urge them to consult a healthcare attorney for the state of Florida first.

Also, if your client owns the Urgent Care Center, and also has a private practice, and wants to refer patients to the Urgent Care Center, your client should consult with a healthcare attorney for the state of Florida.  This situation very easily violates Federal (and state, if they have them) anti- kickback laws unless it is structured properly.