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Medicare Compliance & Reimbursement

Compliance:

Sharing Credentials May Mean Breaking the Law

Question: We recently signed on a new physician at our practice and they’re only contracted with two payers currently. One of the other doctors is frustrated that this new practitioner can’t take on their full share of the workload immediately. The established doctor has advised us to just use their own information when billing the new doctor’s encounters so the new doctor can see all patients. Are we allowed to do that?

Wyoming Subscriber

Answer: There are some situations where providers can bill their services under another physician’s information, and many commercial carriers follow the lead of the Centers for Medicare & Medicaid Services (CMS) when determining when organizations can legally bill services in this manner. Technically, the situation you are describing would be considered fraud and you would be opening your practice up to an uncomfortable visit from a federal agency like the Office of Inspector General (OIG), which can audit organizations.

To avoid this issue in the future, you may want to start credentialing new providers before they start at your office so they are ready to work with all contracted payers on their start date. If that isn’t an option, you could assign the new provider to attend to services that aren’t billable. There’s plenty of work for providers to do that cannot be billed, such as prescription renewal phone calls, discussing test results with patients, postoperative care that falls under global care, peer-to-peer authorization reviews, or completing rounds at a hospital if another physician also saw the respective patient(s) on the same day.

Lindsey Bush, BA, MA, CPC, Development Editor, AAPC