Author Topic: Provider Billing Another Provider  (Read 8958 times)

barb2512

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Provider Billing Another Provider
« on: November 01, 2012, 05:05:31 PM »
I do billing for a mental health counselor, LPC in the state of Texas. We'll call her Counselor A.

Counselor A invites another counselor, Counselor B, to use her office space when it is free and will funnel some of her referrals to Counselor B. Counselor A tells me, her biller, that Counselor B will be seeing the clients and the sessions will be billed under Counselor A. Not under the business or the facility, but using Counselor A's name, tax ID and NPI with no mention on the claim that Counselor B actually saw the client.

This is not a supervision situation. Counselor A calls it 'consulting.' She tells me it is okay to bill it that way. I am sure they will discuss the clients and their situations from time to time. But I am not comfortable.

Any thoughts?

Barbara

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Re: Provider Billing Another Provider
« Reply #1 on: November 01, 2012, 05:33:57 PM »
Quote
Counselor A invites another counselor, Counselor B, to use her office space when it is free and will funnel some of her referrals to Counselor B. Counselor A tells me, her biller, that Counselor B will be seeing the clients and the sessions will be billed under Counselor A. Not under the business or the facility, but using Counselor A's name, tax ID and NPI with no mention on the claim that Counselor B actually saw the client.

Your discomfort is on the money. I would tell her that nicely and then ask if you can have the business structure of this arrangement to run by your attorney <wink>    Another thing bothers me too is when you say Counselor B will get referrals from A, and then A is going to have billing under them.   Right there STARK Flags come up big time.   I probably would flat out just say no, but if you want to tread lightly you should make sure you get a formal statement of their arrangement and run it by your attorney to cover your own *%^
Linda Walker
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rdmoore2003

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Re: Provider Billing Another Provider
« Reply #2 on: November 02, 2012, 03:56:12 PM »
absolutely in agreement with Linda.  OMG, your gut was right, listen to it.
Regina

barb2512

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Re: Provider Billing Another Provider
« Reply #3 on: November 05, 2012, 12:22:52 PM »
Sent Counselor A an email this morning to recap the voice mail message I left her on Friday that she had not responded to:

"" I am not going to be able to bill Counselor B under you unless you provide me with a written explanation of the arrangement between yourself and Counselor B for my records and my attorney to look at.
 
I called the LPC board on Friday to check on cpt codes for 'consulting'. The LPC board says they do not know of a 'consulting' arrangement. They do not know of any arrangement called consulting. They said it sounds like insurance fraud.
 
I am sure you are not contemplating insurance fraud. I tried to reach a couple of insurance companies provider relations but lots of insurance companies were under water with the hurricane up north.
 
You had said that the last time Counselor B was there I billed it and it will be the same as then. But back then I was your employee and you bore the burden of accountability to the insurance companies. I did not have the responsibility of legality. I was able to just do as I was asked.
 
The legality would not have been my liability. Now it is.
 
Now that our relationship has changed and I am not an employee but a separate business, I have the responsibility to make sure all my actions, claim filings, are legal.
 
So with your written and signed documentation I will get legal approval. ""

Tried to sound like I  was giving her the benefit of the doubt since I was her employee for 5 years until October 15th when I went in with a contract and changed our relationship so I can take on other mental health billing counselor/clients.

I always come across as to formal and mean in my emails, I think.

Any thoughts?

thank you,
Barbara

DMK

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Re: Provider Billing Another Provider
« Reply #4 on: November 05, 2012, 01:14:51 PM »
Formal is always best.  You didn't sound mean to me, you sounded professional.  Even with patients I love the most, an official letter from the office is always written formally.

You have to cover yourself because it will be you who is fined, or prosecuted for insurance fraud if you bill what you know to be illegal.  Ignorance of the law is no excuse. 

When I first read the post I thought "So when the patient sues Counselor B for malpractice, but Counselor A is on record as the charging physician, how do you explain?"

barb2512

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Re: Provider Billing Another Provider
« Reply #5 on: November 05, 2012, 04:56:18 PM »
I just spoke to Counselor A who says she is a PLLC which means, she says, that she is a business that can have employees.
Second point- how does this mean that I can bill for sessions her 'employee' has? I am assuming someone on the panel here will know how that works.
I assume it is like a facility, like a regular doctor's office where the nurse or PA sees the client. How is it then billed to the insurance? Does the name of the person providing the service go on the claim form or just the facility name?
Does the person providing the service need to be registered with the insurance company or just the facility?
Any help is greatly appreciated.

Thank you,
Barbara

JenniferPT

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Re: Provider Billing Another Provider
« Reply #6 on: November 06, 2012, 09:50:12 AM »
This is called, in the field, "creative billing."   It is illegal.   just like it is illegal to bill for an individual session when the counselor knows full well they are seeing a married couple, because family sessions are not available on their insurance plan.  I'm surprised how many therapists do this.   Or if a partner isn't insured, they see that person as the insured.   Blows my mind how many times I have new patients call and get miffed with me because "our last therapist did it."   Well...that's nice, but I like my bed and cooking my own dinner.   I have no desire for a jail mattress and food cooked by Bertha who is in the joint for 50 years for murder. 

Print out some legal stuff for her to read and go over and ask her if this is worth her livelihood?   Either Counselor B gets credentialed and in network and bills as herself, of you walk away from this lady.   She's setting you up to be legally responsible for jail time and huge fines.   

Anyone out there is a fool to think the insurance companies don't find this stuff out.  Tons of fraud cases available to see online, for medical billing.   

barb2512

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Re: Provider Billing Another Provider
« Reply #7 on: November 06, 2012, 10:24:25 AM »
Thank you. Every time Counselor A explains it to me I can still come up with a roadblock.

Thank you.
Barbara

DMK

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Re: Provider Billing Another Provider
« Reply #8 on: November 06, 2012, 10:39:37 AM »
The other thing to think about is this...  If the patient sees Counselor B and sues them for malpractice, how do you explain the billing to Counselor A? 

Michele

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Re: Provider Billing Another Provider
« Reply #9 on: November 07, 2012, 06:57:38 AM »
Being a PLLC doesn't change the laws/rules that one provider cannot bill under another providers name/numbers for services provided.  The only time that is legal is if the billing provider is supervising/overseeing the care of a provider under a legal situation.  For example, a PT has a PTA working for them but they are in the room supervising the care given to the patients.
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barb2512

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Re: Provider Billing Another Provider
« Reply #10 on: November 07, 2012, 08:13:52 AM »
Thank you so much.

I appreciate your continuing to respond to this. Please, If something else occurs to you, let me know.

Thank you.
Barbara

rdmoore2003

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Re: Provider Billing Another Provider
« Reply #11 on: November 07, 2012, 02:42:06 PM »
I just wanted to put my 2 cents worth in on this.  I understand how difficult it can be to attempt explaining to providers the why's and why nots of billing.  Your counselor, no matter a, b, etc., does not have any schooling, training, certifications, etc on billing, insurance, or coding.  This is so frustrating to me that a provider thinks they know all but in fact has no clue in most cases.  they can talk to their board all day and night, but the fact remains that billing, coding, etc is much more than they realize and none of this is covered under their ph.d's, masters, whatever.
Regina

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Re: Provider Billing Another Provider
« Reply #12 on: November 09, 2012, 11:33:02 AM »
I have to echo the other responses. You can only tell them so much, what they retain is another story. I don't mind educating providers, it's my job, however when we keep running into a brick wall and they KEEP on trying to find ways AROUND it, that's just my red flag that it's time to let it go. Your email sounded Awesome, very professional, way better than I would have done myself, you gave the benefit of the doubt, did not sound accusatory, Excellent.. JUST one thing. I would back that up with a certified letter adding to it, that "At the current time I feel I can no longer continue..."  If you are going to keep going back and forth with her and she keeps coming up with "the answers" your letting her do your job for you and it makes you second guess your gut and your expertise. IMHO I would have to walk away at this point because it could (like the others explained) land you hot water.  Sometimes doing the right thing is the hardest thing to do. (my mom always told me that)  Just make sure you keep good documentation and if you decide to not continue keep your tone the same as you did in the email. :)
Linda Walker
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barb2512

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Re: Provider Billing Another Provider
« Reply #13 on: November 14, 2012, 01:54:27 PM »
Thank you so much for your thorough answer. I really appreciate you and the time and work you put into the forum.
Barbara