Medicare Physician Supervision and
"Incident-To" Billing Rules
Audio CD

Recorded March 27, 2006

Faculty: Dan Mulholland, Henry Casale & LeeAnne Mitchell-O'Brien

It's 11 o'clock – Do you know where your P.A.s are?

The Medicare program has a number of rules governing when physicians can bill for services that someone else provides. Examples include billing for things that physician assistants and nurses do in the office, anesthesiologists overseeing CRNAs, and technicians handling cardiac stress tests and rehab procedures. But these rules can also arise in more subtle ways. For instance, while the Stark regulations allow physician group practices to lease in-office ancillary services like MRIs and CTs on a part-time basis if the imaging equipment is still in the same building as their office, the supervision rules still apply. So, while sending patients down a few floors for a test may meet the Stark rules, if the required level of supervision is not present, billing problems could result. The penalties under the False Claims Act for violating these rules could be ruinous, and there are whistleblowers under every rock who will gladly call these problems to the attention of the government, maybe even the very people you are supervising. And lest hospitals think this is just a physician problem and they are off the hook, they should think again. Physician supervision can affect hospitals as well, either directly or through joint ventures with physicians.

In this audio CD, attorneys LeeAnne Mitchell-O'Brien, Henry Casale and Dan Mulholland review these rules in detail and tell you what you need to do to comply. Topics covered include:

• Billing for services "incident to" physician services
• CRNA supervision rules
• Cardiac rehab supervision rules
• Physician supervision and the Stark Law: how to avoid the in-office ancillary trap
• Effect of state laws and regulations

Audio CD: $225

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