Anti-kickback statute prohibits physicians and hospitals from asking for or receiving or offering or paying any type of remuneration (including any kickback, bribe, inducement, or rebate) directly or indirectly, overtly or covertly, in cash or in kind in return for referring an individual to a person [physician or hospital] for any item or service.
Billable Services: Those services with an identifiable CPT code such as E/M services (initial inpatient, subsequent inpatient, discharge services & consults) and procedures (PICC line insertions, ABG etc) are all billable services.
All services associated with a surgery including those 24 hours prior and 90 days after a surgical procedure, including the post operative care normally associated with the procedure (e.g. wound care, pain management, etc.
only those conditions not normally associated with the procedure may be separately billable (e.g., tachycardia 2 days after an amputation).
Susan Jones, PA, is employed by Metropolis Memorial Hospital to follow orthopedic surgical patients during their inpatient stays. Susan’s supervising physician is the Chief of Orthopedics, a university faculty practice plan physician who is not an employee of the hospital. Susan regularly rounds on the orthopedic patients to be sure their pain is managed well; complications are avoided or addressed as early as possible; and a discharge plan is in place, constantly reevaluated, and updated as needed.
May Susan provide these services or do they impermissibly induce physicians to send their patients to MMH?
May Susan perform the admitting history and physical? If so, who may bill and collect for it?
May Susan write pain management orders? If so, who may bill for the pain management services she provides?
May Susan put in a PICC line if the patient develops an infection? If so, who may bill and collect for it?
May Susan discharge the patient? If so, who may bill and collect for it?
Brittany Sticks, NP, is employed by David Community Hospital to cover emergent needs of inpatients during the night. Her collaborating physician is an employee of the hospital as its Chief Medical Officer. She is called to see patients when their attendings and hospitalists are not available. Typically she evaluates patients with new onset of chest pain, fever and chills, hypotension, injuries from falls, and performs procedures such as arterial blood gas collections or replacing PICC lines.
May the hospital bill and collect for the procedures that Susan performs such as inserting PICC lines? If not, who may?
May the hospital bill for the consultations Susan does? If not, who may?
May Susan provide services if the hospital cannot bill for them?
John Garrison is an employee of Mt. Olive Medical Center and an RPA-C with special training and experience in neurology. Typically he cares for in-patients on a special neurology floor for epilepsy patients by rounding twice a day, ordering and interpreting diagnostic tests, writing medication orders after conferring with attending physicians, and assuring discharge plans are developed. The physicians who admit patients to the special unit come to the floor every day.
May the hospital bill for John’s services when he rounds on the patients twice a day? If so, what may it bill? If not, who may bill for the services he has provided?
If John writes progress notes each time he rounds to evaluate the patients and if he discusses the findings with the attendings, may the attendings bill and collect for the services if they document that they have “Reviewed and concur with above.”?
Palms of Pasadena Hospital is trying hard to attract a pulmonology group to provide specialist services. Being located in a depressed area with one of the highest rates of heart and lung disease in the country, the hospital desperately needs pulmonologists to care for its inpatients. The hospital has hired nurse practitioners to help the pulmonologists it has because there just “aren’t enough of them to go around.”