# Can you bill MRI's as incident to?



## 1073358 (Jun 18, 2014)

Can MRI be billed as incident to?


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## mitchellde (Jun 18, 2014)

I do not see how.  Can you elaborate a little?


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## dclark7 (Jun 19, 2014)

According to the Medicare Benefit Policy Manual, 100-02, chapter 15, section 80; Diagnostic tests benefits fall under a different part of the SS Act (sub sec 1861(s)(3)) than incident to benefits (sub sec 1861(s)(2)).  They do not need to meet incident to requirements, but have their own set of requirements regarding physician supervision. http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c15.pdf


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## 1073358 (Jun 19, 2014)

*clarification*

Let me be a bit more clear. If a PA sees a patient, determines they need a MRI and go ahead and order it, can the TC portion of the MRI be billed out totally under the MD's name rather then the PA's name?

I know my gut feeling, but am looking for written guidance. I read the above policy, but i am still not clear. 

Thanks all.


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## MarcusM (Jun 20, 2014)

Modifier -26; Professional Component, usually billed by the radiologist who interprets the imaging.
Modifier -TC; Technical Component, billed by the facility for use of their equipment. If the radiologist works for the facility, then the whole component is billed.
Just ordering the MRI is not a separate billable event as it is included in the E&M code.


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## 1073358 (Jun 20, 2014)

MarcusM said:


> Modifier -26; Professional Component, usually billed by the radiologist who interprets the imaging.
> Modifier -TC; Technical Component, billed by the facility for use of their equipment. If the radiologist works for the facility, then the whole component is billed.
> Just ordering the MRI is not a separate billable event as it is included in the E&M code.



I am questioning billing the TC component itself. We have the MRI in our clinic. We do the TC and then someone else reads it for the 26.


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## mitchellde (Jun 21, 2014)

You will have to use the PA as the ordering provider in field 17


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## OCD_coder (Jun 21, 2014)

I have seen this same question asked several time recently in the forum.  

The PA cannot report the TC portion of the MRI, this is beyond their scope and so only the supervising physician can report the TC component.  It has to do with the type of supervision they (radiology procedures) need.  Per the Centers for Medicare & Medicaid Services (CMS) Internet Only Manual (IOM) Publication 100-02, Medical Policy Benefit Manual, Chapter 15, Section 80. 


*PER CMS:*
This is effective for those claims that are billed as non-incident to the physicians service. When the PA or NP is listed as the servicing or rendering provider, it has been determined that billing the technical component of an x-ray is not within the PA/NP scope of practice. 

If the PA/NP billing is submitted to Medicare as a non-incident to service, the PA/NP NPI can be reflected as the servicing or rendering provider for the professional component of the x-ray using the AMA-CPT code for the x-ray and Modifier 26. The technical (TC) component must be submitted showing the NPI of the supervising MD/DO on another line of the claim. 
https://www.aapc.com/memberarea/forums/showthread.php?t=102369
http://www.aapa.org/WorkArea/DownloadAsset.aspx?id=2222


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## 1073358 (Jun 23, 2014)

*safe assumption*



OCD_coder said:


> I have seen this same question asked several time recently in the forum.
> 
> The PA cannot report the TC portion of the MRI, this is beyond their scope and so only the supervising physician can report the TC component.  It has to do with the type of supervision they (radiology procedures) need.  Per the Centers for Medicare & Medicaid Services (CMS) Internet Only Manual (IOM) Publication 100-02, Medical Policy Benefit Manual, Chapter 15, Section 80.
> 
> ...






Is it safe to assume if a PA can NOT bill the TC part of a MRI, that they can NOT bill the global charge either? (since global is tc and PF)


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