Wiki IDTF billing???... I NEED HELP

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I have a bad bad feeling about something and need some advice...

My pain management physician decided he wanted to have an Independent Diagnostic Testing Facility. He hired a few radiology technicians, sent them to surgery centers to perform flouroscopy during his (and other physicians) epidural injections and wants to bill for TC services of flouro and x-ray his reasoning is that he has a contract with and pays rent to the ASC that leases the equipment and that gives him the right to bill for the TC component. He says this is done by "everyone" but in the 10 years I've been in billing and coding I've never heard anything like it although I've never billed for an IDTF or radiology practice.

I've tried to explain bundling and that when the ASC ireports 64483 (or whatever code) part of the reimbursement is for the flouro TC component and by submitting another claim for the same services by a different entity we're not in compliance and could get in a lot of trouble. I've read and shown him on the CMS 855B where it states that services performed in an ASC setting should not be reported and I've over and over shown him the American College of Radiology definition of IDTF is to provide DIAGNOSTIC services NOT services to assist in the direct treatment of a patient.

He's pushing forward with Medicare enrollment and I'm at my wits end arguing with him.... He's convinced that because he's gotten payment on some Worker's Comp claims and some commercial ins claims that he's in the right and CMS is wrong. Blue Cross has denied every claim with the reason being the only payable services at the facility would be professional and some of the smaller worker's comp carriers are stating to deny stating duplicate services... he wants me to appeal; I want to run for the hills.

I need some advice please. Honestly, a small part of me thinks he may be right but I've been unable to find any evidence of that from any source. I'm seriously considering being a "whistleblower", contacting the government to report suspected fraud before he gets in too deep. What should I do?
 
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