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OPPORTUNITY BIG REIMBURSEMENT FROM MEDICARE -$2,100

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diagnostico:
Thanks for all of your feedback PMRC.
Will the lockbox be a substitute for the surety bond?
Is there a legal loophole around the "reassignment" issue?

diagnostico:
Couldn't I just contract the lab out to do the sample processing and bill the insurance company as if I were the lab? C

RichardP:
The doctor is sending the samples to a lab hired by us to process the samples.shouldn't that. Matter?

It does matter.  But this is the point where you need a health-care attorney who is very familar with both the Federal and your state laws against self-dealing.  You are still facing the technical and professional issue though.  If you are not certified as a lab, you cannot claim the technical component - because you did not do the work.

[Edit]

Couldn't I just contract the lab out to do the sample processing and bill the insurance company as if I were the lab?

No.  Your healthcare attorney will tell you why not - but bottom line, you can't claim to have done the work when someone else actually did it.  Well, you can - until you get caught and sent to jail.

PMRNC:
I was going to say exactly what Richard said, these are legal questions best answered by both YOUR attorney and the lab's attorney, there are many many factors to consider, I cannot see how you could just bill the carriers as a non medical supplier.  But again, these really are some very heavy legal issues you want to discuss on both sides to cover both of you.

RichardP:
diagnostico - a lab cannot get paid by Medicare unless it has a CLIA number.  Medicare has mapped a given CLIA number to the Type 2 (who gets paid) NPI number of the lab owner.  Further, they then map the CLIA and NPI numbers to the address where payment should be sent.  Medicare will not issue payment unless the CLIA number and NPI number on the HCFA form match exactly what they have in their system.  Given that they match, they will send payment only to the owner of the NPI number on file.

For you to receive payment, you must break the relationship outlined in the above paragraph.  It is possible to do this, but you have some significant hoops to jump through in order to do it successfully.  That is why you need a healthcare attorney who knows his/her stuff.  If you don't do it correctly, you won't break the relationship outlined in the above paragraph, and payment will continue to be sent to the lab.

The rules for non-Medicare carriers are probably looser than Medicare's.  But the carriers tend to mimic what Medicare does.  So you probably need to do something similar with them as well.

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