Wiki Provider is Billing both POS 72 and POS 11 on the same day and same member

[kmshea321]

I have two claims where the same rendering provider is split billing. One with POS 72 (FQHC) and one with 11 (Office) with the same physical address for same visit on same date of service. The Doctor also owns this FQHC. Is this normal for a provider to bill this way to get more money instead of the just the encounter rate for the FQHC claim and all other services would normally global. However, he is billing the EM on one claim and the lab/path tests on another claim to get more money? This is a Medicaid plan. Is this considered FWA?

 

[Orthocoderpgu]

I code orthopedic surgeries, so this is a bit outside of my norm here. Are you thinking that this is a Stark violation? Initially it does not make sense to me. Is a FQHC allowed to process labs that would not be allowed in a normal doctor office (POS 11)?