Practice Management Alert

Question: Our practice recently hired a new doctor who has privileges at the local hospital and is seeing patients but is not yet credentialed with the insurance carriers. One of our credentialed physicians has been signing off on the new doctor's charts. Are we allowed to bill for the new doctor's services under the ID number of the physician who signed off on the charts? What other option do we have?

 - South Dakota Subscriber

Answer: To bill under another doctor's number, that doctor must be ultimately responsible for the patient's care. Signing off on the chart is important as far as proving responsibility for care, but the physician under whose ID number you're billing also needs to provide clear evidence he has had face-to-face contact with the patient at some point. The patient should be well aware that this physician is temporarily overseeing her care, even though the new doctor at your practice will provide the patient's day-to-day treatment.

You probably can't justify billing under your credentialed physician's ID number if he simply discusses the patient's plan of care with the new doctor, or if he calls the patient only to inform her of the fact that he is taking over her care. Face-to-face contact is a must. And remember, incident-to rules don't apply here because they pertain to the relationship between a physician and a nonphysician provider, and both providers in this situation are physicians.

To prevent this difficult circumstance, you should make sure to establish a new physician's insurance ID numbers ahead of time (see Article 1). This will save you from an uncomfortable transition period when carriers won't accept claims from your new doctor. And once Medicare approves your new physician's personal identification number, the carrier will actually pay retroactively on all the claims filed on or after the date you applied for the new provider's number. Private-payer policies on retroactive reimbursement will vary.

Editor's note: For further explanation of retroactive billing and what actions to take when a new physician signs on, see the cover story "New Physician Doesn't Have to Mean New Billing Problems."