You Be the Billing Expert:
Does Some SNF Billing Violate Stark Laws?
Published on Mon Jan 18, 2010
Question: My physician is the medical director for a skilled nursing facility and receives a stipend from the SNF for that service. Can he still bill for services he provides to the SNF's patients? Nebraska Subscriber Answer: Since you're dealing with directorship of the skilled nursing facility (SNF), which is a facility, you first need to look at Stark regulations. Fortunately, in this case, you shouldn't have to worry about potential Stark violations when you bill for the physician's service in the SNF where he is the medical director. Why: Medical directorships usually involve a set of advisory and oversight responsibilities that aren't directly tied to the care and treatment of a single patient, but rather the entity as a whole as an administrator. Your physician can admit his own patients to the SNF and can see them in the SNF setting without interfering with his medical director responsibilities. Caveat: [...]