PYA Principal Lyle Oelrich is quoted in the Report on Medicare Compliance May edition in an article that details various billing and Stark compliance issues around advanced practice providers (APPs) and physicians. In “CMP Settlement: Services ‘Personally Performed’ by Mid-Levels Were Attributed to Doctor,” Lyle notes the use of APPs is becoming more prevalent. Under Medicare, services performed by APPs can be billed under several different models. In billing for APPs under incident to, split/shared services, and global billing, hospitals who employ physicians must also satisfy a Stark Law exception. Part of the employment exception deals with services being “personally performed” by the physician, which may be complicated when APPs collaborate with physicians to see patients, and those physicians are on a productivity compensation methodology.
“People need to understand what the Stark definition of personally performed actually means,” [Lyle] said. “It is still misunderstood by some in the industry.” When physicians and APPs collaborate—through incident-to billing, split/shared services and global billing—they have to tread carefully with Stark when it comes to productivity compensation.
Read the full article here.
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