fellow tele-radiology moonlighting

[DOFOSHO]

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[maxxor]

is it unlawful/uncool/shady for a radiology fellow with a TRAINING license in state A to perform tele-radiology services for states B, C, and D in which he is FULLY licensed and insured? Does anyone have personal experience with a situation similar to this?

This is illegal. You must have a full license both where you are located and where the scan was acquired.

 

[DOFOSHO]

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[m2k]

This is illegal. You must have a full license both where you are located and where the scan was acquired.

This is interesting. I'm not aware of any such law. Do you have any reference? It is normal if you're living in one state, chances are you have the license.

 

[m2k]

I've done more research on this since the original post. Its actually not illegal. However, the ACR (they don't write laws) suggests that one has licensure at both the transmitting and receiving states.

It seems logical. Tele-rad companies would definitely know and/or might require you to have license in your state just as their policy.

 

[maxxor]

It seems logical. Tele-rad companies would definitely know and/or might require you to have license in your state just as their policy.

1. If you want to bill CMS, you must bill in the state where the interpretation is performed with claim filed to that MAC. You cannot bill CMS on a training license.

2. This is state to state, but the vast majority of states require someone to have a state license for practice of medicine in their state as teleradiology is still the practice of medicine. During covid a lot of stuff was temporarily waived with regard to telemed licensure, but there is a reason vRad/ other telerad guys require multiple licenses. The 2 states I have licenses for require you to have full unrestricted licenses as telerad is regulated under “telemedicine” rules.

3. The ACR requires licensure for both. This may not matter if you are not an ACR member, but if the site undergoes ACR accreditation that can threaten their accreditation.

If you are only doing prelim work, it’s murkier but isn’t worth the hole you are digging for yourself.
Get a proper license for your current state.

 

[DOFOSHO]

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[maxxor]

the scenario for this is a PRN job during fellowship - getting paid directly by the group and not individually billing CMS.

Are you doing final reads or not?

Even if the group bills CMS on your behalf and accepts reassignment, you need a full license to submit to the MAC.

Basically, the grey area is prelims.

 

[DOFOSHO]

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[maxxor]

This person will be doing final reads. This person already does final reads for numerous states in which he has full licensure from his apartment in a state in which he only has a training license - there has never been a billing issue (or any issue). This has been done for over a decade by other residents/fellows in the same program and there has never been an issue.

Good luck. I’d not want to be the test case for that CMS RAC audit.

Now if you wanted some qui tam cash, you could probably report it.

Edit: CMS guidelines are pretty explicit on this fact.

https://www.cms.gov/medicare/medicare-fee-for-service-payment/physicianfeesched/downloads/faqs-cr7631-4-25-13.pdf

 

[Taurus]

Most fellowships are 1 year long. Don’t screw up your career by playing games with your licenses or insurance. It’s like rushing into marriage. You’ll just regret it later.

 

[Cognovi]

Just get a full license in state A jeez

 

[qwerty89]

You could always try VA NTP if you live in one of a handful of cities. Just need any state medical license.

 

[DOFOSHO]

deleting your posts lmfao. eyeroll

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