Physician Billing Compliance: On-Call Queries

After hours coding? Here's a word of caution: Youparty is not compensating him for his time,
can't catch ER coverage services with after-hourssuggests Barbara J. Cobuzzi, MBA, CPC, CENTC,
codes. If you bill the wrong way when yourCPC-H, CPC-P, CPC-I, CHCC, president of CRN
physician covers for others — or for thatHealthcare Solutions, a coding and reimbursement
matter when another physician covers for yourconsulting firm in Tinton Falls, N.J., and senior coder
physician — you could be setting yourself upand auditor for The Coding Network.
for charges of fraud.For instance: If your office closes at 5 p.m. but
Avoid the hassle: Keeping in mind these fewyour physician sees a patient on an emergency
simple answers to the top three on-call billingbasis at 7 p.m., you should report 99050 in
questions will help you correctly file claims.addition to any other services provided. You
1. Which doctor bills for the services?should not report 99050 if your physician saw the
If your physician is on call and handling patientpatient in the emergency room at 7 p.m.
services for another physician, don't make the3. Can billing be skipped altogether?
mistake of letting the other physician bill for theYou may be desirous to simply arrange a
services. Although a patient sees a particularsubstitute arrangement with other practices for
physician, that does not imply that the physicianyour physicians to cover for one another at
can bill for any services related to that patient'svarious times. This, however, sets your practice
care. When your physician provides a service, youup for financial liability and lost reimbursement.
should bill the services even if your physician is on"Reciprocal billing" works only for two practices
call for another doctor.that have similar size practices with similar patient
Bobbi M. Bohon, CPC, of Seven Hills Surgical inand similar acuity and whose doctors perform
Lynchburg, Va, says, "I bill for those billable visitsnearly equal coverage.
when my surgeon is on call and covering for theReason behind: This type of arrangement saves
other surgeons in town."on paperwork, but it isn't realistic to assume that
Verify the NPI: Joseph A. Lamm, office managerthe workloads between the physicians will all even
for Stark County Surgeons in Massillon, Ohio,out over time. One physician might end up with a
suggests "Each doctor who sees a patient shouldvery time-consuming patient to deal with. So
bill for the appropriate services rendered under hisassuming that the inequities will all balance out in
her own NPI (National Provider Identifier) number."the end just doesn't work. Each physician should
Hint: Bohon says, "The physician who sees thebill for the work he performs.
patient face to face and documents and signs hisHint: Lamm says, "You may desire to have a
her name should bill for those services providedhealthcare attorney to review your on-call billing
regardless of who the admitting surgeon is."arrangements to ensure that you're not
2. How to report on-call ER services?fraudulently reporting services." However Medicare
Many times, physicians tend to patients in thedoes recognize "reciprocal billing" and even has a
emergency department while on call. Don't run formodifier to indicate when you are participating in
the after-hours codes to bill these services whenreciprocal billing. You can use modifier Q5 (Service
the hospital pays your physician for being on-call.furnished by a substitute physician under a
Reason behind: You cannot bill twice for thereciprocal billing arrangement) to indicate to your
physician's services if the hospital is already payingMedicare carriers that you're participating in a
him to be on-call physician in the emergency roomreciprocal billing arrangement, Cobuzzi says. Private
(ER). You should bill the after-hours codes 99050payers, on the other hand, don't require a
(Services provided in the office at times othermodifier when you're doing reciprocal billing.
than regularly scheduled office hours, or daysImportant: Cobuzzi concludes, "Remember that by
when the office is normally shut [e.g., holidays,using the Q5 modifier, you are telling Medicare
Saturday or Sunday], in addition to basic service)that the billing physician is not the actual rendering
and 99058 (Service[s] provided on an emergencyphysician, as without a modifier, a private payer
basis in the office, which disrupts other scheduledwho has not given you a sanction in writing for
office services, in addition to basic service) onlyreciprocal billing may interpret it as billing for
when your physician sees a patient in your officeservices that were not provided.
outside regular office hours and another third