# Residents billable "after hours" in ED setting?



## ghejnal (Jan 21, 2010)

Hi all,

I am looking for official guidelines or a website somewhere that states that residents are billable *ON THEIR OWN* without having to have attending documentation during the following hours: Monday-Friday after 4:30 or 5:00pm (I'm unsure which time), weekends and holidays.  

I was taught as an ER coder that residents are separately billable, only during the times listed above, however, I have no documentation to prove that.  Is there a guideline, or an article that supports this?  Can someone please help, or point me in the right direction?  Is this a current billing practice?  I appreciate whatever assistance is given.  

Thanks so much!
Grace Bower, CPC


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## eadun2000 (Jan 21, 2010)

I personally have never heard of such a thing.  I was under the impression that a resident cannot bill without a teaching doctor.  Maybe somebody else knows.  I am curious to see what anybody can find out.


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## LLovett (Jan 21, 2010)

There is no after hours in an ED setting. To be an ED you have to be open 24/7.

http://www.cms.hhs.gov/MLNProducts/downloads/gdelinesteachgresfctsht.pdf

Above is the MLN matters on teaching physician guidelines. The only time you can bill for a resident stand alone is in an approved GME primary care setting and they can go no higher than a level 3.

Unless someone can provide something else that I am not aware of you can not bill for stand alone residents services in the ED.

Laura, CPC, CPMA, CEMC


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## ghejnal (Jan 22, 2010)

I appreciate all of the help and completely agree.  I wonder if this is just an Ohio rule.  I can't seem to find anything to justify this, either.  But I know some coders in Ohio who follow this.  I prefer concrete evidence to justify my coding.  Thank you all!


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## LLovett (Jan 22, 2010)

I worked in Ohio from 1999-2008, never heard of this before. 

How are they billing them, under the teaching physician?

You will get paid if you do this but that doesn't make it correct. If you get audited you will be in trouble unless there is something else out there that I am not aware of.

Laura, CPC, CPMA, CEMC


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## geigerk (Jan 22, 2010)

Could it be that this is getting confused with the fact that a resident can (and does) moonlight in EDs quite often - outside of their scope of residency?

Many residents make extra money by becoming independent contractors and working night shifts in the ED.  Once they have their internship completed and have that MD, they qualify to get reimbursement in their own right.  You do have to credential them.  If it is outside the scope of the work they do for their residency, you can get provider numbers and bill for them independently.  

Outside of this scenario, there is no such rule that residents can bill after hours.


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## ghejnal (Jan 24, 2010)

geigerk said:


> Could it be that this is getting confused with the fact that a resident can (and does) moonlight in EDs quite often - outside of their scope of residency?
> 
> Many residents make extra money by becoming independent contractors and working night shifts in the ED.  Once they have their internship completed and have that MD, they qualify to get reimbursement in their own right.  You do have to credential them.  If it is outside the scope of the work they do for their residency, you can get provider numbers and bill for them independently.
> 
> Outside of this scenario, there is no such rule that residents can bill after hours.



I believe my original post should've referred to moonlighting.  Is there a document somewhere that can confirm your post's information regarding billable residents who moonlight in the ED after hours?  Thank you.


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## geigerk (Jan 25, 2010)

I would check the provider enrollment application and manual section for provider enrollment.  Once you apply for a number by Medicare and they get that number, you are free to bill for them for any hours outside of their scope of residency.  It must be billed under their own provider number. 

Medicare only requires an MD for credentialing, some managed care may require more, but I imagine they are used to the "moonlighting scenario" in the ED.


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## geigerk (Jan 25, 2010)

I would check the provider enrollment application and manual section for provider enrollment.  Once you apply for a number by Medicare and they get that number, you are free to bill for them for any hours outside of their scope of residency.  *It must be billed under their own provider number.  *

Medicare only requires an MD for credentialing, some managed care may require more, but I imagine they are used to the "moonlighting scenario" in the ED.


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