Billing Question about In-Office Bundled Payments

[VTPain]

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Have been in a private practice for over 10 years now and was recently approached by a partner in our multi specialty group about how our bundled payments for procedures in the office are handled.

Essentially the question was are in-office bundled payments actually a separate professional fee and facility fee or just one bundled payment. Our practice is eat what you kill. The pain docs in our group have always billed for and collected our bundled payments because we are exclusively in office and pay all the associated overhead for staff, c-arm, supplies, etc.

My partner’s assumption is that in-office procedures technically include a “facility” component even though the payments are bundled; he thinks it is no different from the ASC or hospital. He also believes it is possibly a Stark violation for the pain docs to keep the “facility” component for themselves because the entire office building (i.e facility) is owned by all the partners (15 of us, a mix of pain, ortho, Neuro).

Can’t imagine he could be correct on this, but wanted to run it by you guys as well. All the pain docs I have trained with and known for years have never separated out in-office procedure payments to professional and facility components.

Appreciate the feedback- have been a long time follower here dating back to med school days but first time poster.

 

[painfree23]

Have been in a private practice for over 10 years now and was recently approached by a partner in our multi specialty group about how our bundled payments for procedures in the office are handled.

Essentially the question was are in-office bundled payments actually a separate professional fee and facility fee or just one bundled payment. Our practice is eat what you kill. The pain docs in our group have always billed for and collected our bundled payments because we are exclusively in office and pay all the associated overhead for staff, c-arm, supplies, etc.

My partner’s assumption is that in-office procedures technically include a “facility” component even though the payments are bundled; he thinks it is no different from the ASC or hospital. He also believes it is possibly a Stark violation for the pain docs to keep the “facility” component for themselves because the entire office building (i.e facility) is owned by all the partners (15 of us, a mix of pain, ortho, Neuro).

Can’t imagine he could be correct on this, but wanted to run it by you guys as well. All the pain docs I have trained with and known for years have never separated out in-office procedure payments to professional and facility components.

Appreciate the feedback- have been a long time follower here dating back to med school days but first time poster.

He’s wrong. In office reimbursements are higher for the physician fee than in an ASC bc there is no “facility fee” in a clinic . All goes to physician but all ur costs come out of that (needles/trays/meds except steroid)

 

[RoloTomassi]

He's a jealous hater trying to take a bite of your pie because his cases can't be done in office. In office there are not two parts, just a pro fee. Referring to these pro fees as "bundled" isn't even accurate. No Stark issues whatsoever.

 

[callmeanesthesia]

That’s complete BS. while technically you could separate out the pro fee (what you’d get paid in a facility) and subtract it from the global office price to get a “facility fee” of sorts, there is no Stark law violation there. It isn’t a surgery center. Is he going to give you a big chunk of all his office visits? Those have a facility rate too. Didn’t think so.
In short, just tell him he’s FOS, it’s not a Stark violation and you’d be happy to have the group’s lawyer confirm that if necessary (on his dime), and if the surgeons try to implement it, you’ll leave the group.
(This fires me up a bit because we have one surgeon in my group who is constantly trying to dump expenses on me and my PM&R partner)

 

[Ducttape]

show him the ASIPP guidelines on their website ASIPP.org and show him the payments. in particular show him that there is nothing separate for physicians in office.

 

[drusso]

He’s wrong. In office reimbursements are higher for the physician fee than in an ASC bc there is no “facility fee” in a clinic . All goes to physician but all ur costs come out of that (needles/trays/meds except steroid)

This is correct. No office facility fee. But, maybe there should be as the Medicare Economic Indices (MEI) used to account for costs in ASC and HOPD SOS are different than office SOS and the office SOS does not index for inflation.