# Auditing Billing Variance



## jsims (Mar 20, 2013)

We are a small RHC with four providers and two mid-levels (APRNs).  We were recently audited and informed that we had a number of billing variances, i.e. the rendering provider's name (midlevel) was not on our MC claims.  We bill it this way as our midlevels are not contracting with MC and therefore don't have their own MC number.  Our program lets us put in the billing provider and the service provider but the service provider's name does not appear on the claim.  We were told that the service provider's name needed to appear in field 24G although I don't believe that is the correct field.

Any ideas or suggestions?


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## mitchellde (Mar 20, 2013)

The provider rendering the service goes in 24J.  unless this is incident to.  If this is an incident -to claim then the provider in this practice that saw this patient for the same dx goes in field 17 with the DN qualifier for referring provider and the supervising provider goes in 24J.  If this is a new patient or a new dx or an exacerbation of an exisiting dx then you cannot bill under the physician NPI in 24J it must be the NP NPI.


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## jsims (Mar 20, 2013)

mitchellde said:


> The provider rendering the service goes in 24J.  unless this is incident to.  If this is an incident -to claim then the provider in this practice that saw this patient for the same dx goes in field 17 with the DN qualifier for referring provider and the supervising provider goes in 24J.  If this is a new patient or a new dx or an exacerbation of an exisiting dx then you cannot bill under the physician NPI in 24J it must be the NP NPI.



Debra, thanks for the quick response!  What about on a UB claim?


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## mitchellde (Mar 20, 2013)

you cannot bill incident to on a UB it must be billed using the PA or NP NPI number as the rendering provider.   You cannot bill the facility setting the same as in an office setting.


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## jsims (Mar 22, 2013)

mitchellde said:


> you cannot bill incident to on a UB it must be billed using the PA or NP NPI number as the rendering provider.   You cannot bill the facility setting the same as in an office setting.



We are an Independent RHC and therefore we bill our MC office visits to Cahaba on UB claims but when it is a midlevel providing the service we put the midlevel as the service provider and the physician as the billing provider (as the midlevels do not have MC numbers) but it does not show the service providers name on the claim.  Any other suggestions?


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## mitchellde (Mar 22, 2013)

That is what I am saying, I believe you must use the NPI of the rendering provider.  I do not think you can bill the way you are, the billing variance is for billing more than 24 hours of care per day for the physician.  You have to use the Service provider as the billing provider.  Why are your NPs not contracted with MC?


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## jsims (Mar 27, 2013)

mitchellde said:


> That is what I am saying, I believe you must use the NPI of the rendering provider.  I do not think you can bill the way you are, the billing variance is for billing more than 24 hours of care per day for the physician.  You have to use the Service provider as the billing provider.  Why are your NPs not contracted with MC?



Our NPs were contracted with MC but then when we became a RHC those numbers were dropped for some reason.  Some commercial payers do not accept midlevel numbers.  We have asked our RHC consult about this and he is currently getting a second opinion on this.  Thanks again for all of your help.


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