Wiki IDTF Billing PLEASE HELP

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My doctor started an IDTF thinking it's going to make him money. He employed some radiology techs and sent them to ASC's to provide flouroscopy and xray services to patients having surgical procedures. He told these ASC's that we will bill the TC componants of all services provided, recieve payment from the carrier and the ASC will pay nothing. He did not do any research into the billing specifications or compliance guidelines before starting this company.

I've not previously done IDTF billing and I've been reading some things that scare me.

On the CMS-855b it states "procedures performed in an facility setting that are clearly surgical in nature should not be reported" Also, we have one supervising physician to act as a general supervising physician but my Dr. thinks that's all that is required and because he has a permit to own and operate a flouroscopy machine that makes him the supervising physician although he's performing the actual procedure. We have no one acting as personal or direct supervision except for the performing physicians.

Our techs are doing a lot of flouroscopies for ESI's and other similar procedures, using 77002 and 77003 to bill for needle localization. Also angiographies and simple X-Rays.

We've recieved denials from various carriers all stating that because the TC compontant was billed at an ASC setting, there is no seperate payment. This makes a lot of sense considering NCCI but still my Dr is convinced we can and should be paid for these; he states all the time "everyone is doing it". I'm so confused and overwhelmed at this point. I've showed him anything I can find but everything I find tells me these services are NOT billable. Still he refuses to admit defeat and now wants me to look for another code that might be billable.

One tech put me in contact with an IDTF biller who stated there's a "gray area" but what this gray area is she won't tell unless we pay $1500.00 for her consultation.

My first question is are IDTF's allowed to bill for the TC componants of radiologic procedures performed at ASC's? Second, for the procedures done in office, if we don't have a Radiologist as supervising can the performing physician be the "supervising" physician?

My head and heart are telling me no to both but any advice from someone familiar with this is appreciated. Please help!
 
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