# Who can bill for moderate sedation?



## HBROCKMAN (Apr 9, 2013)

We are starting to bill for a new group of physicians, in Florida, and they were told by Medicare that doctors are not allowed to charge for IV sedation during their procedures unless the RN providing that sedation is employed by the physician.  

My question is:
The RN's are employed by the hospital...should this group be billing for this if they do not employee the RN?

I truly have no idea, and have spent half of the day trying to find some website that will say...only charge this if you employee the RN, unfortunately I never found it.  If anyone can answer this or send me a link to an article...that would be wonderful!!

Thank you so much in advance!
Heather, CPC


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## Michele Hannon (Apr 10, 2013)

Note that the moderate sedation codes describe services provided by "the same physician performing the diagnostic or therapeutic service" or "provided by a physician or other qualified healthcare professional other than...."

In 2013 the AMA established a definition for a Qualified Healthcare Professional (QHP) in terms of what provider may report services: A "physician or other QHP is an individual who is qualified by education, training, licensure/regulation (when applicable), and facility privileging (when applicable) who performs a professional service within his/her scope of practice and independently reports that professional service."
These professionals are distinct from clinical staff. A clinical staff member is a person who works under the supervision of a physician or other qualified healthcare provider and who is allowed by law, regulation and facility policy to perform or assist in the performance of a specified professional service, but who does not individually report that service. 
An RN does not independently report services and would therefore be considered clinical staff.
Guidance from the AMA.


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## HBROCKMAN (Aug 21, 2013)

I do understand that they are clinical staff...but they are not our clinical staff, the RN is employed by the hospital.  Are they saying that since they do not report independently for their services, with the fact that we do not pay their salary, does not matter.  And that the physician should bill for this service because he was supervising a hospital employee...??  I am sorry...I don't know why this is so difficult for me to get through my head...it has just been one of those days!


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