The Third Party Care Committee will be posting newsworthy health care information and noteworthy coding tips every month. We welcome the opportunity to help you with your coding conundrums. Submit your coding questions to the VOA Third Party Care Committee Chair, Dr. William Kossol, at WKOSSOL@AOL.COM . Selected questions may be posted on this site so we can share information. This feature is a service to VOA members and is offered for advice and guidance. Enjoy and remember to submit your questions.
(Please consult appropriate authorities in that neither the VOA or Dr. Kossol are responsible for the accuracy of any responses. Responses reflect information according to posting date.)
Locum Tenens (posted March 7, 2011)
Our inaugural post is a question from an OD in Chesterfield:
I have a question for you. Do you know if you have a doctor filling in at your office for an extended period of time, and that doctor is not credentialed with any insurance companies, can the fill in doctor see the patient and then one of the credentialed doctors also sign the chart so the insurance can be billed under the credentialed provider's name? I seem to be getting conflicting answers from insurance companies, our insurance coordinator at our office, and other doctors. I didn't know if you may know the answer, or if you know someone who would.
Locum Tenens -a physician who is contacted to work on a temporary basis to fill in for a vacancy, vacation, or extended leave.
Payment Under Locum Tenens Arrangements-
Physicians may retain substitute physicians to take over their professional practices when the regular physicians are absent for reasons such as illness, pregnancy, vacation or continuing medical education, and for the regular physician to bill and receive payment for the substitute physician’s services as though he performed them himself. The substitute physician generally has no practice of his own and moves from area to area as needed. The regular physician generally pays the substitute physician a fixed per diem amount, with the substitute physician having the status of an independent contractor rather than of an employee. These substitute physicians are generally called “locum tenens” physicians.
These guidelines do not apply to providers other than physicians (i.e., Certified Registered Nurse Anesthetists (CRNAs), Physical Therapists (PTs), etc.).
The patient’s regular physician may submit the claim and (if assignment is accepted) receive the Part B payment for covered-visit services (including emergency visits and related services) of a locum tenens physician who is not an employee of the regular physician and whose services for the regular physician’s patients are not restricted to the regular physician’s office if:
- The regular physician is unavailable to provide the visit services.
- The Medicare beneficiary has arranged or seeks to receive the visit services from the regular physician.
- The regular physician pays the locum tenens for his services on a per diem or similar fee-for-time basis.
- The substitute physician does not provide the visit services to Medicare patients over a continuous period of more than 60 days.
Q6 Modifier Payment Under Locum Tenens Arrangement
The regular physician identifies the services as substitute physician services meeting the requirements of this section by entering the HCPCS Q6 modifier (services furnished by a locum tenens physician) after the procedure code.
If the only substitute services a physician performs in connection with an operation are postoperative services furnished during the period covered by the global fee, these services need not be identified on the claim as substitute services
** Make sure the substitute doctor has valid and appropriate malpractice insurance
BAD DEBT WRITE OFF (posted March 7, 2011)
This is a great post for the tax season:
In our optometric practice we end up writing off some patients balances as bad debt. How can we legally write off bad debt? Should we be sending those patients an IRS 1099-C form?
(A 1099-C form is a cancellation of debt form. IRS instructions state that “if a federal government agency, financial institution, credit union, or an organization having a significant trade or business of lending money (such as finance or credit card company) cancels or forgives a debt you owe of $600 or more, this form must be provided. “)
I asked my CPA for a response to this question. I’m not sure if he billed me for the time it took to write this, but his answer is dead on.
“In today’s economy, it has never been more important to understand the specifics behind the tax rules for claiming deductions for bad debts. For many businesses, trade and other receivables represent some of the largest assets on the balance sheet. In this period of economic downturn, the possibility increases that taxpayers won’t be fully paid for accounts receivable.
In order to mitigate the financial impact of debts gone sour, it is important to understand the tax provisions applicable to worthless bad debts. What is considered a bad debt to the taxpayer may not necessarily represent a bad debt in the eyes of the tax authorities. In addition, taxpayers’ bookkeeping practices with respect to tracking receivables is also critical in determining the amount and timing of bad debt deductions.
The first factor to consider before claiming any bad debt expense is whether the taxpayer reports on the cash or accrual basis. A cash basis taxpayer generally has no basis in its trade receivables since no tax was ever paid on the revenue and, therefore, no tax deduction is allowed. This often comes as a surprise to certain taxpayers, but once it is understood that income was never reported on the receivable in taxable income, they tend to grasp the concept then no deduction is allowed. An accrual basis taxpayer can claim bad debts to the extent they charge off all or a portion of specific receivables. Accrual basis taxpayers pay income tax on revenues as earned and not collected, so when the receivable is deemed to be uncollectible and the amount is charged off the books, a deduction from income is allowed since it was previously reported as income. Cash basis gives one the luxury of paying tax only when the income is received but in turn creates no tax benefit to writing off the receivable, while an accrual basis taxpayer is required to pay tax on income when earned whether received or not, they get a deduction once the receivable is deemed worthless and written off.” Daniel J. Bender, CPA/PFS, CFP® PBGH, LLP
You should not send a 1099-C form to a patient when you write off their bad debt-even if doing so would make you feel better. In fact, you could even get in serious trouble if the patient gets upset and goes to the IRS about the incorrect 1099. If you want to collect bad debt from the patient, you need to take that patient to small claims court or hire a collection agency to pursue the patient.
SIMPLE TIPS FOR QUICK REIMBURSEMENT FOR CATARACT CO-MANAGEMENT (Posted April 12, 2011)
I have fielded several calls from ODs receiving denial letters for cataract co- management care. The number one reason for denials historically has been the OD reporting a different diagnosis code than the ophthalmologist. Avoid across the board use of 366.10 (senile cataract, unspecified). Call the surgical coordinator of your MD after you see the patient post operatively and retrieve the precise diagnosis and surgical CPT codes they will be using. Surgical procedure code 66984 applies to the majority of cataract patients whose procedure went smoothly, but the surgeon may report 66982 if the case was more complex. If your codes don’t match the surgeon’s code, you will not get paid.
While on the phone with your surgeon’s office, ask if they are filing for any of the post operative care and if so for how many days so you can bill for the balance (90 day global coverage for cat post op). The OD assumes care the day after the patient is last seen by the surgeon-even if you have not seen them yet. It wouldn’t hurt to remind them that they should be using modifier 54 (surgical care only) when they file their claim. You should be using modifier 55 (post operative management only) with either procedure code 66984 or 66982 on your claim.
For co-management reimbursement, know that Medicare considers the 90 day period following cataract surgery reimbursable at 20 percent of the overall procedure charge. To figure out your split- first calculate 20 percent of the overall charge and divide that total by 90- this gives you the per day value of your post operative care. Multiply that by the number of days of post op care you provided.
If your Medicare patient had cataract surgery on her left eye on March 1, 2011 and the surgeon releases her to your care on March 9th, and your follow up care includes 84 days of service, part of her 1500 form should read:
- Line 17 enter surgeons name
- Line 17b enter surgeons NPI
- Line 19 write Assumed post-op care 3-9-11 through 7-1-11 (these dates must match the number of days you will enter on line 24g)
- Line 21 enter diagnosis code
- Line 24a enter dates of service
- Line 24c leave blank
- Line 24d enter procedure code and modifiers (for above example enter 66984-55-LT)
- Line 24g enter the number of days of your service (for above example we used “84”)
- Line 24j enter your NPI
Tip- To keep it simple-file your claim for each eye on separate 1500 or electronic claim forms.
POST OP REFRACTION CHARGES FOLLOWING CATARACT SURGERY? (Posted April 12, 2011)
A colleague from Luray asks: “Is it permissible to charge for a post op refraction in addition to the post op care following cataract surgery. Is it commonly done?”
Seems like a simple question, doesn’t it?
The CMS manual, under “Components of a Global Surgical Package” defines post operative care as –“Follow-up visits during the post operative period of the surgery that are related to recovery from surgery”. I don’t see the word refraction there. What I do see is the commitment for the OD to medically treat the surgical eye back to good health during the 90 day global coverage period.
I did a small phone survey (5 calls): Medicare’s response via phone call was “post operative refraction is covered under the 90 day global coverage period”. No surprise there. Phone calls to two of my favorite cataract surgeons drew opposing responses- one office said refraction probably was included, the other office said refraction is not medical care and we could probably bill for it. The reply from a very “Smart” optometrist’s office was they now “include the refraction at no charge as a courtesy, but I may have to rethink that.”
What do I do in my practice? I throw in the refraction at no charge and hope to heck they visit my optical shop for that new pair.
WHERE DO YOU FIND THE NEW MEDICARE FEE SCHEDULE? (Posted April 12, 2011)
An optometrist from Hurt, VA asks “I am trying to locate a new copy of the 2011 allowable Medicare fee schedule. Can you point us in the right direction?”
As of March 19, 2011, Virginia Medicare providers transitioned from Trailblazers to Palmetto GBA. Medicare is now Jurisdiction 11 Medicare Administrative Contractor, Palmetto GBA. Important info to know:
- New Medicare phone number (to speak to a representative) is 866-830-3043.
- New IVR number (interactive voice response) is 888-414-8592.
- New Medicare web site is www.palmettoGBA.com/medicare. The Fee schedule has not changed and can be found under the “Top Links” tab on the bottom right of the Jurisdiction 11 Part B page.
MEDICAL VISIT TURNS INTO VISION PLAN EXAM (Posted April 12, 2011)
“A female patient came in to my office with the chief complaint that she was concerned about macular degeneration. Her mother has it and is undergoing treatment and she also has 2 uncles with ARMD. She stated her vision was fine with her current RX. A comprehensive exam was done including dilated retinal evaluation. No pathology was noted. At the end of the exam macular degeneration was discussed, as well as giving the patient a brochure from the AOA concerning vitamins, and recommendations given. At the end of the exam, it was realized she has Eyemed vision care. (My staff usually does a good job of determining this beforehand). Since no pathology was found, can I bill it medically, using a symptom code? Or do I take it on the chin and just bill it as a vision exam? (Just to make it interesting, if I bill it medically, the patient pays out of pocket because it will probably go towards her deductable) I do realize that if her medical denies her refraction, we can then bill her vision carrier for the refraction only, but so often they put the refraction towards the deductable as well which removes that option. Thank you for opinion? Advice?” OD in Lynchburg
This exam, in your words, should be “taken on the chin”. You can’t file a medical exam without a medical diagnosis. But you my friend have made every full scope practicing optometrist proud. You addressed your patients’ chief complaint, examined her thoroughly, educated her and gave her peace of mind. EYEMED appreciates it- you gave them a 50% discount off your regular exam fee by being one of their providers, your patient appreciates it- your thoroughness may generate more referrals and kind words, and your colleagues all appreciate you upholding high eye care standards. Put a gold star on your forehead. You shined.
ONE FOR ALL AND ALL FOR ONE (Posted April 12, 2011)
“Do all the doctors in a professional corporation, billing using the same tax ID, have to be participating providers in a major medical plan (Anthem, Aetna, Cigna) for one doctor to participate? For example, can I participate with Anthem and bill for things like Topography, OCT, etc. while my partner who doesn't participate bill the patient in full for vision therapy? Thanks for your insights.” Dr. P and Dr. P
If you are all billing under your professional corp’s Tax ID, then everyone using that Tax ID has to participate and accept the contracted fee schedule for services. Doesn’t seem right, does it?
Today’s third party care posts were brought to you by the letter “K” ….