Author Topic: Billing for an "associate?"  (Read 3344 times)

Christy

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Billing for an "associate?"
« on: January 09, 2013, 10:36:16 AM »
HI!

I was speaking to a chiropractor who has his own pratice and hired an "associate" (another DC). He said this person performs services, but it is billed under his (the owner DC) name.

is this legal and how do you bill in this fashion?

thanks! :)

DMK

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Re: Billing for an "associate?"
« Reply #1 on: January 09, 2013, 12:04:42 PM »
No, this isn't legal.  You must bill the services under the doctor performing the service's ID.  EVEN vacation relief OR Locum situations.

RichardP

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Re: Billing for an "associate?"
« Reply #2 on: January 10, 2013, 12:07:20 PM »
Both question and answer are not clear to me as they do not address the issue of NPI numbers.

From Page 61 of this CMS link:

[Edit:  as of 4-18-13, the following quote is found under Section A of Page 59]

http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c01.pdf

The question of reassignment arises only when assigned payment is made to someone other than the physician or other practitioner or supplier that furnished the services.

A supplier may be an individual, partnership, corporation, trust, or estate. Any services furnished by an employee of the supplier are considered furnished by the supplier if those services are within the scope of the employment.   [end quote]

Doctors groups may hire physicians and pay them a salary.  A doctor who has incorporated may hire physicians and pay them a salary.  A doctor acting as a sole proprietorship may hire physicians and pay them a salary.  All work done is billed under the name of the hiring group or physician.  The hiring group or physician gets paid and then pays the hireling(s) a salary.

One of the points of the NPI numbers was to make this relationship more clear to CMS.  Hence the Type 1 (who did the work) and Type 2 (who gets paid) NPI numbers.  Both must be used on the CMS 1500 form that is submitted to Medicare.  One tells CMS who did the work, and the other tells CMS who gets paid.  In the case of a solo practitioner, both of the NPI numbers provided on the CMS 1500 form belong to him.  In the case where the work was actually performed by a hireling, the CMS 1500 form must contain the Type 1 NPI number for who did the work (the hireling), plus the Type 2 NPI number for who gets paid (the hirer).

On the CMS 1500 Form, the Type 2 NPI number for who gets paid goes in Box 33.  The Type 1 NPI number for who did the work goes in Box 24J.  The Type 1 NPI number for the referring doctor goes in Box 17a.  This is how we do it and we have no problems getting paid.

Perhaps all of this was implied and understood in the previous exchange.  If that is the case, my apologies for being dense.

[Edit on 1-24-13; changed from Box 24K to Box 24J two paragraphs up.]
« Last Edit: April 18, 2013, 08:42:56 PM by RichardP »

DMK

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Re: Billing for an "associate?"
« Reply #3 on: January 10, 2013, 12:25:54 PM »
RichardP,  You clarified it perfectly.  The "associate" (and in Chiropractic practices there are LOTS) should have his own NPI as the performer of the services, the facility can get the payment under their Type 2 NPI. 

You CAN NOT bill it "as if" the owner did the services.  And a good way to explain it to the doctor who owns the place is the malpractice issue.  If the patient sues, they're going to sue the doctor who performed the services.  The associate has to have his or her own malpractice insurance too. 

PMRNC

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Re: Billing for an "associate?"
« Reply #4 on: January 10, 2013, 02:11:09 PM »
Always make sure you get the full legal structure of each practice. How a practice is legally setup makes a big difference. I don't get into all this. I just ask to see their group paperwork if there is a question.
Linda Walker
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RichardP

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Re: Billing for an "associate?"
« Reply #5 on: January 10, 2013, 03:47:15 PM »
I just ask to see their group paperwork ...

For those who may not know - for CMS purposes, a "group" has a specific definition.  A solo practitioner, or a single doctor who is incorporated, can hire  as many doctors as he has business for and that setup is not considered a "group" by CMS.
« Last Edit: January 10, 2013, 03:49:08 PM by RichardP »

PMRNC

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Re: Billing for an "associate?"
« Reply #6 on: January 10, 2013, 05:07:50 PM »
That to me is NOT my concern. I meant that if there is a question I want to see how they are setup. I don't get into the middle of their setup.. I only have purpose to know I'm billing properly.
Linda Walker
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JAZH

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Re: Billing for an "associate?"
« Reply #7 on: January 10, 2014, 10:40:30 AM »
I am new to this forum. My questions is along the same lines. I work at a 2 physician practice- one is the owner and one is paid a percentage of the work her does. We started using a new practice management software that is linked to our EHR in May. In preparing for the attestations for the EHR incentive it came to my attention that everything has been billed using only the owners NPI number. Apparently our biller was told to do it that way. 1) Can we continue to bill this way if we do not intend to apply for the incentive money for both physicians? 2)If we do need to correct this can we just go back and correct enough claims to qualify for the incentive or are we required to go back further? I would appreciate any input since we are now on a tight timeframe as far as the attestations. Both physicians are eligible and saw enough patients to qualify for the full incentive.

PMRNC

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Re: Billing for an "associate?"
« Reply #8 on: January 10, 2014, 02:31:03 PM »
Quote
I am new to this forum. My questions is along the same lines. I work at a 2 physician practice- one is the owner and one is paid a percentage of the work her does. We started using a new practice management software that is linked to our EHR in May. In preparing for the attestations for the EHR incentive it came to my attention that everything has been billed using only the owners NPI number. Apparently our biller was told to do it that way. 1) Can we continue to bill this way if we do not intend to apply for the incentive money for both physicians? 2)If we do need to correct this can we just go back and correct enough claims to qualify for the incentive or are we required to go back further? I would appreciate any input since we are now on a tight timeframe as far as the attestations. Both physicians are eligible and saw enough patients to qualify for the full incentive.

Richard summed it up pretty good:
 
Quote
Type 1 (who did the work) and Type 2 (who gets paid) NPI numbers.  Both must be used on the CMS 1500 form that is submitted to Medicare.  One tells CMS who did the work, and the other tells CMS who gets paid.  In the case of a solo practitioner, both of the NPI numbers provided on the CMS 1500 form belong to him.  In the case where the work was actually performed by a hireling, the CMS 1500 form must contain the Type 1 NPI number for who did the work (the hireling), plus the Type 2 NPI number for who gets paid (the hirer).

I'd say you might have to go back and fix things from the very beginning in addition to doing it right now.

Linda Walker
Practice Managers Resource & Networking Community
One Stop Resources, Education and Networking for Medical Billers
www.billerswebsite.com