Bass, Berry & Sims attorney Shannon Wiley, with Carine Leslie and Katie Garmon of PYA, P.C., recently discussed the complexities associated with billing, coding, and collecting for infusion services as part of the Infusion Insights Webinar Series. As billing, coding, and collection errors can lead to insurer recoupments or potentially devastating False Claims Act, Anti-Kickback Statue (AKS), and Beneficiary Induction Civil Monetary Penalty Law (CMP) violations and associated penalties, infusion providers must ensure that their businesses comply with all applicable requirements.
The speakers discussed billing and coding practices for infusion centers adopting a Non-Physician Practitioner (NPP) business model. To facilitate a smooth billing process, NPP infusion centers must use the appropriate Current Procedural Technology (CPT) codes when billing for various infusion services and properly distinguish claims for primary and sequential items. Infusion providers must also identify certain highly complex drugs that may be subject to additional billing or supervision requirements imposed by commercial payors or Medicare Administrative Contractors (MACs) and ensure compliance with any payor or MAC-specific obligations.
Shannon explained Medicare Part B “incident to” billing requirements for physicians and nurse practitioners providing infusion services. These requirements impose specific supervision and treatment obligations necessary for providers to legally bill for drugs...
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