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Cardiac US, Professional Interpretation and Global Billing Print E-mail
Written by Benjamin L. Frosch   
Friday, 20 December 2013 09:54

Medicare Q & A 

Q:   I am an Administrator at a Cardiology practice that is purchasing an ultrasound machine and radiology equipment to perform procedures in our office. We will satisfy the necessary supervision requirements with a non-radiologist. However, we will have a radiologist perform the professional interpretation off-site in Jacksonville. If we hire the radiologist on a part-time basis, will our group practice be allowed to bill Medicare globally for the procedures? If not, under what circumstances can we bill globally?


Broward Cardiology Practice

A.   Let's start with the issuance of transmittal 2679 on March 29, 2013 which addresses place of service (POS) radiology services. Global billing is allowed (assumes technical/professional components are provided in the same payment locality) presupposing that the radiologist reassigned their benefits to the group.

Global billing would not be allowed when the technical is rendered in locality 3 (Broward) and the interpretation is rendered in Jacksonville (locality 2). The claim should list a line item with the technical component assigning a "TC" modifier. The professional service should be indicated as a separate line item with a "26" modifier. You would need to indicate the zip code for the professional service on the claim to Medicare since the interpretation was rendered in locality 2 (Jacksonville), which happens to have a lower payment then locality 3.
With respect to the physician working on a part-time basis in lieu of purchasing the services, you may have an issue with the Stark regulations or even some state laws. The radiologist may be required to provide these interpretations on the site of your practice. There may also be an issue with anti mark-up if these services are reimbursed on a "per test basis". You may want to check with a seasoned healthcare attorney to assure that you comply with all of these complex rules, regulations, and guidelines.

Mr. Frosch is the President of Frosch Medical Consultants in Plantation, FL.  Got a Question for Ben?  Click Ask Ben.

Last Updated on Friday, 07 February 2014 11:03
Interest Charged on Overpayments? Print E-mail
Written by Benjamin L. Frosch   
Monday, 16 December 2013 10:51

Medicare Q & A with Ben Frosch

Q:     I just received a letter from Medicare informing me of a substantial overpayment. My staff researched this issue and we concluded they are correct with the overpayment determination.  

The letter we received states that it is a follow-up letter. I never received the initial notification of an overpayment from Medicare. 
My question addresses the interest on this overpayment. What are the rules on Medicare assessing interest on an overpayment?

Miami, FL

A:     Medicare does not charge interest on overpayments that are received within thirty-days. After the thirty day period, interest is assessed for the first thirty-day period and an additional thirty-day period. Interest continues to accrue for each subsequent thirty-day period for which payment is not received by Medicare.  When money is offset (withheld from Medicare payments), it is applied to the accrued interest first and then to the principal. The follow-up overpayment letter probably does not imply you have another thirty-day period to refund the amount nor does it prevent Medicare from withholding future payments after the thirty-day period has elapsed. If you do not refund the overpayment within forty-days from the date of the initial refund request letter, Medicare may initiate offsets and pursue other efforts of recovery of the identified overpayment.

The bottom line is, once you receive notification of the overpayment; return the monies as quick as possible. The overpayment is considered a debt owed to the United States Government and you can always appeal if you feel that Medicare is incorrect with the allegations of the overpayment or the interest payment. 

About the Author 
Mr. Frosch is the President of Frosch Medical Consultants, Inc. in Plantation.  Got a question for Ben? Click Ask Ben. 

Last Updated on Monday, 16 December 2013 10:58
Locum Tenens and the 60 Day Rule Print E-mail
Written by Benjamin L. Frosch   
Wednesday, 18 September 2013 16:35

Medicare Q &A

Q:   We have a Locum Tenens physician who next week will be with us for sixty days. It is our understanding that sixty days is the "Medicare" cutoff for a Locum Tenens physician which allows us to use the Q6 modifier.   The provider enrollment process is very cumbersome and I was wondering if once our Locum Tenens physician reaches the sixty day period, can the Locum Tenens Physician take a day off and the sixty day Medicare period begin again?

-Office Manager

Palm Beach, FL

A:  If the regular physician requires services of a Locum Tenens physician for a period longer than sixty days, the substitute physician needs to enroll with the group practice. The Locum Tenens physician should complete a CMS 855R reassigning his/her benefits to the practice.   Otherwise, the substitute physician "taking a day off" is not a consideration in the Medicare guidelines of Locum Tenens for establishing the sixty day period.  

CMS guidelines state that a regular physician may bill for the services of a Locum Tenens physician providing that the following guidelines are met;

A.    The regular physician is unable to provide visit services.

B.    The substitute physician does not provide services over a continuous period longer than sixty-days.

C.    The Medicare beneficiary has arranged for or seeks to receive services from the regular physician.

D.    The regular physician pays the Locum Tenens for services on a per diem or similar fee for time basis.  

About the Author 
Mr. Frosch is the President of Frosch Medical Consultants, Inc. in Plantation.  Got a question for Ben? Click Ask Ben.
Disruptive In-Office Emergency Visits Print E-mail
Written by Benjamin L. Frosch   
Monday, 09 September 2013 12:35

Medicare Q & A

Q:   We try to provide our patients with the highest quality of care. For our established patients, we have started to treat them on an "emergency" basis after hours at our office. Is it necessary for us to attach modifier 25 (indicating a significant, separately identifiable E/M visit on the same date as another procedure) to our follow-up visits in order to additionally bill Medicare procedure code 99058 (services provided on an emergency basis in the office, which disrupts other scheduled office services in addition to basic service)?

-Office Manager

Boca Raton, FL

A:  CPT code 99058 is not a recognized service that is billable to the Medicare program. The E&M follow-up visits will have to be billed according to the actual level of care that is provided to the patient. There is no additional reimbursement by Medicare for disruption of other scheduled services or after hour services in your office.

 About the Author 
Mr. Frosch is the President of Frosch Medical Consultants, Inc. in Plantation.  Got a question for Ben? Click Ask Ben.

Last Updated on Saturday, 14 September 2013 15:39
Surgeon Inquires About Appeal Print E-mail
Written by Benjamin L. Frosch   
Friday, 30 August 2013 17:49

Medicare Q & A

Q.  I am a non-participating surgeon. I performed a surgery on a Medicare beneficiary that was very complex and time consuming.   Because the claim was submitted unassigned, the beneficiary received the payment which was very low for the surgery performed. The patient is elderly and would have difficulty filing an appeal. Can I file the appeal on behalf of the beneficiary?


South Florida

A.  Yes, under certain circumstances. The beneficiary may complete an appointment of representation form (CMS 1696) which can be found at

This form is used to authorize an individual to act as a beneficiary's representative in connection with a Medicare appeal. As a representative, you would be able to help your Medicare patient during the processing of the claim and any subsequent appeals. 

About the Author
Mr. Frosch is the President of Frosch Medical Consultants, Inc. in Plantation.  Got a question for Ben? Click Ask Ben.
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