Author Topic: NPI BOX 24J  (Read 1598 times)

surfergirl

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NPI BOX 24J
« on: December 02, 2014, 08:08:58 AM »
I was not quite sure how to start a new post so please forgive me if I have posted twice by accident :)
Good Morning Medical Billers. I am an independent biller and my client is a Mental Health group practice that is exploding and very successful.
My question is when a new Doc comes on board the head Doc of the practice asks me to bill under her rendering NPI in Box 24J until they are credentialed and then can be linked to the group. In the meantime she supervises her new clinician and this is her justification.
I am concerned about liability. Should I be? I have been billing for 14 years and have never encountered this scenario.
Is there anyone out there that has had this happen to them. My goal is to advise my client of the appropriate and legal steps not to mention my own liability.
I appreciate any and all feedback.
Thank you and happy billing.
Respectfully,
SurferGirl

RichardP

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Re: NPI BOX 24J
« Reply #1 on: December 02, 2014, 08:53:05 PM »
... when a new Doc comes on board ... bill under her (hiring doc) rendering NPI in Box 24J .

Can you do this?  Yes
Are you likely to get caught?  No

Is this legal?  No.

Type 2 NPI Number is for who gets paid, and goes into Box 33a on the CMS 1500 Form.

Type 1 NPI Number is for who did the work, and goes into Box 24J.

Box 31 on the CMS 1500 Form contains the signature of the physician who did the work, stating that all information on the form is true.

  1.  If hiring physician signs here, he is claiming that he did the work - by virtue of signing and his Type 1 NPI Number in Box 24J.  If he did not do the work, this constitutes fraud.

  2.  If new-hire physician signs here, he is claiming that he did the work and that the NPI Number in Box 24J is his.  Since that NPI Number is not his, this constitutes fraud.
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Note that none of the above applies to non-physician employees.  What you have described is permissible for non-physician employees and is referred to as "incident to" billing.  You can Google that phrase and read about it.

Also - in California, the only carrier who wants an NPI # in Box 24J that we do business with is Medicare.  That modifies the fraud of Point 2 above a bit - in that there would be no Type 1 NPI Number in Box 24J for non-Medicare carriers.  So the signer would not be claiming it was his.  He would only be claiming that he did the work - which would be true.

Health-Care Attorneys are your friend in situations like this.  They are likely to tell you not to do it when the new-hire is a physician.
« Last Edit: December 02, 2014, 08:57:54 PM by RichardP »

surfergirl

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Re: NPI BOX 24J
« Reply #2 on: December 09, 2014, 08:16:27 PM »
Thank you very very RichardP. Your response has been extremely helpful.
Happy billing.