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Non-credentialed providers

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Michele:
If the provider is not yet licensed and is being supervised then yes it can be billed under the supervising PhD.  Just check state laws too to be safe.

PMRNC:

--- Quote ---If the provider is not yet licensed and is being supervised then yes it can be billed under the supervising PhD.  Just check state laws too to be safe.
--- End quote ---

BE EXTREMELY cautions with these.. I have had 2 clients in the past that were "supposed" to be supervising, caught them not adhering when the supervising provider (PHD) went on a 2 week fishing trip, yet I was getting faxed claims. As per my attorney since I KNEW the supervising provider was NOT supervising it was blatant fraud and I'd be responsible for claims filed at that point (because I knew).  I had to terminate the client ON the spot and report it to cover my ass since it was likely they were doing it all along. didn't want to report it but my attorney said it was the only way to ensure I was protected from previous fraud I may have billed.   I had another client .. SAME exact scenario except they decided to tell me it was ok since his wife would be in the office (and she was not a provider. lol).. had to terminate them as well as they refused to listen to me.     Remember that you are JUST as responsible in those situations as the supervising provider. Be aware, be alert and MAKE SURE YOUR CONTRACT PROTECTS YOU

Angie:
Thank you Linda!
I actually am employed by them so I don't have a contract and I don't work on site I work from my home for them. Would I be held liable if I prepared something and didn't know if they were being supervised or not? or would it be my employer? To my knowledge she is being supervised and all of the notes are signed by her and the supervising MD but since I am not there to actually witness it......Little scary....Any suggestions?
Also we are OON with all insurance companies and are private pay; it is clearly stated in our contract and the clients pay at the time of service so we are good there we only provide these statements for the patients that request them as they are trying to seek reimbursement from their insurance companies.

PMRNC:
your contractual relationship is of NO matter to the federal government under Anti=kickback and fraud statutes.. There have been MANY independent consultants, billing companies and even salary/hourly paid employee's held individually responsible.


--- Quote ---Would I be held liable if I prepared something and didn't know if they were being supervised or not? or would it be my employer?
--- End quote ---

You are both responsible, they are responsible NOT to break the law and you are responsible for knowing what's going on. There is no room for ignorance when it comes to fraud/abuse, the law says you SHOULD know.  A good contract will help drive this fact home (though it wouldn't protect you, just make it known to the client you won't tolerate any funny business)


--- Quote ---To my knowledge she is being supervised and all of the notes are signed by her and the supervising MD but since I am not there to actually witness it......Little scary....Any suggestions?
--- End quote ---

Well, I always advise to make sure you keep good documentation, have good Errors & Omissions insurance and make sure your client is fully aware of your responsibilities and theirs via a SOLID good contract.  Even a suspicion of something not right could be cause for concern if you file claims with that suspicion. Bottom line is you don't want to find out the hard way so protect and cover yourself.   I'm not saying there are not legit physicians doing this of course, there are.. I'm just saying to beware of possible situations that could arise.  A good compliance plan will also include situations like this that you could refer to if/and when you have to.

 

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