Billing for contracted Dr's at a second location

[cstinnett]

Several physicians have been hired as part-time contractors (as opposed to employees), to work at a second location.  The Doctor/Owner is not at the second location while the contracted physicians are working.  The Dr/Owner has been billing under his NPI # and not indicating that the services were provided at the second location by another provider.  Are there any billing or legal implications for this? 
Someone told the owner that if the patient charts are stored at the main location then there is no need to report that the services are provided at the second location and since the new doctors are not technically employees of the company there is no need to report them as being the provider, is any of this true?   

[bobbie]

No, that doesn't sound right. They need to show the location of services and the NPI of the actual rendering provider. If they're independent contractors then they use their own tax ID too. I'd be careful on this one don't be apart of his potential scam. Just doesn't smell right. I know alot of times doctors talk amongst themselves about billing stuff. My experience is that they typically don't know what they're talking about because they got their information from someone else who doesn't know what their talking about either.
It just doesn't sound good, trust your instincts on this one

[cstinnett]

I know this is an unusual situation. Thanks for your input.

[sherry27]

Several physicians have been hired as part-time contractors (as opposed to employees), to work at a second location.  The Doctor/Owner is not at the second location while the contracted physicians are working.  The Dr/Owner has been billing under his NPI # and not indicating that the services were provided at the second location by another provider.  Are there any billing or legal implications for this? 
Someone told the owner that if the patient charts are stored at the main location then there is no need to report that the services are provided at the second location and since the new doctors are not technically employees of the company there is no need to report them as being the provider, is any of this true?   

They are not allowed to do this. bobbie is right. Sometimes dr's want to play stupid. For this to be done correctly, the 2nd location needs to be added to the practice and it will be given a seperate npi for that location. You can still have the same Tax Id since it is the dr owns it and it is considered the same group. The rendering providers need to be added to the additional location. Call up the insurances and get them credentialed or contracted.    If the dr does not want this done, i would be letting them go.

[melissa_2004]

I agree with Bobbie and Sherry.  This situation has red flags all over it.  Remember CYA.  Also make sure you document any conversations you had/have regarding this to keep for your records. 

[Michele]

The provider rendering the services must be indicated on the claim by using his individual NPI in the rendering provider NPI field (box 24J on the CMS).  All other comments are correct too.  This is not correct.  Actual place services were performed must also be indicated.  Provider was misadvised.

Michele

[PMRNC]

In those cases I don't go back and forth with the provider. I advise them to speak with their attorney's and hammer it out and call me when they get it right.