Medicare protocols

This has to do with Medicare protocols. This is in regards to physician owned foundation billing under one TIN.

The physician owned foundation was told by a billing specialist, in order to preform diagnostics testing on referring physician outside their group, must have a consult first by one of the groups physicians before the procedure can be done. I question this because I know there are several owned physician facilities that are not required to do so. Facilities such as physician owned surgery centers, physician owned scanners and eye centers that are not IDTFs, don't require consults prior to doing testing on patients outside their practice. Is this practice correct? Also if the facility is billing with TC and 26 modifiers, can this be eliminated by billing globally?

Nathan’s Answer

The answer to your question cannot be answered specifically since the question is too broad. The answer depends heavily on the areas of medicine implicated, the willingness of all parties to abide by CMS's attempted eradication of consultation codes on various types and levels, and whether billing globally is allowable considering the specific services in question, whether the consultation is a true consultation or merely a transfer, and ancillary issues related to Stark/AKS. Please consult with an attorney who has coding compliance experience.