Xray billed

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Posts: 54
Joined: Wed Aug 27, 2014 1:32 pm

Thu May 17, 2018 3:21 pm

If an organization own the x-ray equipment and employs the technician, but sends the films out to be read by a radiologist who volunteer his services to the organization, he do not charge for his service, he is not paid by the organization (strictly voluntary service) nor does he bill any insurance, can the organization bill for the global service or only the TC component?
Posts: 11
Joined: Fri Apr 13, 2018 11:54 am

Thu May 17, 2018 6:19 pm

Hi brownlee47,

Personally, I think it should NOT be billed. IF a provider is doing something Pro-bono, that part of the service should not be billed just because no one is billing that services to any payer. I see this similar to donated medical products and samples from medical companies.

Having said that, if this was in a hospice care, it COULD be billed. I have attached the guidance from CGS Medicare.

Billing Hospice Physician and Nurse Practitioner (NP) Services
Medicare allows for hospices to bill separately for physician's services in the following situations:

The services are related to the patient's terminal diagnosis; and
The physician is a hospice employee, contracted with the hospice, or a hospice volunteer
; and
The services are professional, hands-on care.
The information below identifies the type of service provided by the physician, and whether the service is separately billable to Medicare by the hospice agency. The data elements to bill physician and nurse practitioner services are also listed below.[/i]

One concern I do have is if this could violate Anti-kickback Statute. By volunteering his services to this organization, will he get future patient referrals to his own company/clinic. Another issue I have seen is the provider getting significant discount in rent for "volunteering" his service. Either one of these scenario could violate this statute and implicate Fraud. I would make sure that his contract is reviewed by a healthcare attorney just to be on the safe side of the law.

I hope this helps.
Billing Hospice Physician and Nurse Practitioner (NP) Services.pdf
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Corporate Compliance Analyst
Seattle Children's Hospital
Seattle, WA
Posts: 54
Joined: Wed Aug 27, 2014 1:32 pm

Fri May 18, 2018 7:34 am

Thank you so much for your insight, We are on the same page.
We were in agreement that you can't bill for something that you got free and had decided that billing the TC component only.
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