Summary

In this episode, Sean Weiss discusses the complexities surrounding ancillary providers and their billing practices, particularly focusing on CMS and commercial payer rules. He explains the definitions and roles of ancillary staff, the intricacies of incident to billing, and the compliance requirements for split shared services. The conversation emphasizes the importance of understanding these regulations to ensure proper reimbursement and avoid potential pitfalls in healthcare billing.

Takeaways

• Understanding the roles of ancillary staff is crucial for compliance.
• CMS defines ancillary staff as non-independent billers.
• Incident to billing allows non-physician services to be billed under a physician's NPI.
• Direct supervision by a physician is required for incident to billing.
• Split shared services have specific requirements for billing under a physician's NPI.
• Documentation must capture substantive portions of services provided.
• Regular audits of staff roles and job descriptions are necessary.
• Understanding payer guidelines can help avoid billing denials.
• Compliance gaps can lead to recoupments and legal issues.
• Healthcare attorneys can assist with complex compliance issues.