Assistant Surgeon Not Eligible Codes

[Gibbons86]

We have a surgeon requesting we bill for his PA anytime she assists with surgery, including the non-eligible codes per CMS. Originally the request was for Work Comp payers, now they are wondering why we dont just bill everything out to all payers even though they may not get reimbursed and will certainly cause more work on our end with those increase of denials. Do you have any compliance info on what may occur if we start billing all services to all payers for a Physician and his PA regardless of CMS guidelines for AS? Does this put our clinic at higher risk of being flagged for audits or other issues? The question is mostly focused on Assistant Surgeon guidelines, but I am certain this will expand beyond that into all services and supplies to ensure we are capturing all revenue so if you can provide links/resources to any additional compliance/legal resources regarding billing not only non-eligible codes that will be edited out by the payer, but also any bundled/included supplies and procedures as well. Thank you!!