Rad onc supervision, the epilogue

[maxxor]

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Thanks, just found that on Aunt Minnie. Pertinent quote:

"However, if the interpretation takes place in a different payment locality, split PC/TC billing (attaching modifier -26 for the PC) must be used with the location of each component reported separately. An unusual or infrequent location, such as a hotel or other vacation location, is not to be entered on claim forms; instead, the address of the physician’s most common practice location is to be used."

Are you doing this on vacation or because you live / own / lease property across state lines?

RACs love to audit and you never know when they come sniffing.

 

[Ray D. Ayshun]

Are you doing this on vacation or because you live / own / lease property across state lines?

RACs love to audit and you never know when they come sniffing.

vacation. Just trying to have an answer for every possible reason they can try to deny me billing codes. If the latter I'd just get another license.

 

[maxxor]

vacation. Just trying to have an answer for every possible reason they can try to deny me billing codes. If the latter I'd just get another license.

In that situation, it’s down to the state if they consider scan interpretation “practice of medicine” even if it’s for patients outside the state.

Most do since teleradiology has been for 20 years at this point.

 

[Ray D. Ayshun]

In that situation, it’s down to the state if they consider scan interpretation “practice of medicine” even if it’s for patients outside the state.

Most do since teleradiology has been for 20 years at this point.

So you agree that we shouldn't approve images while away on vacation? I'm perfectly fine with it if that's what everyone is doing. But it ain't.

 

[maxxor]

So you agree that we shouldn't approve images while away on vacation? I'm perfectly fine with it if that's what everyone is doing. But it ain't.

Personally, I have 8-10 licenses and got a Florida license because I go there fairly frequently. I don’t read for any patients in FL but I would rather pay the license fee than be nervous about doing something gray zone over $1000.

 

[TheWallnerus]

Worrying over CMS or an auditor trying to claw money back because, somehow, quite strangely and suspiciously, they found out that the day you were not in the office you were over the state line, in a different state, is... well, a weird worry.

Anything is possible though. Keep in mind those image checks are gonna cost (max) about $25-30 per check in 2026. Big Brother may lose interest in tracking rad oncs' comings and goings.

Working in Kansas City, MO, and living in Kansas City, KS... sounds like checking images from home would be a nightmare (w/o a Kansas license).

Fifty plus years from now our kids' kids will be checking images during their one week vacations in low earth orbit. Wonder which state license they'll need for that.

 

[maxxor]

I'm not worried about CMS just "noticing". I'm worried about Qui Tam suits more than anything. People will rat you out. Don't give them the opportunity.

These are a legitimate worry in Radiology. Almost all the big DOJ radiology settlements are qui tam actions.

 

[TheWallnerus]

I'm not worried about CMS just "noticing". I'm worried about Qui Tam suits more than anything. People will rat you out. Don't give them the opportunity.

These are a legitimate worry in Radiology. Almost all the big DOJ radiology settlements are qui tam actions.

No one will rat anyone out for checking a few hundred images per year out of state. In other words, qui tams are really not going to be taken up by an attorney unless at least a million or more is on the line. And the DOJ won’t join the case for anything less etc.

Let’s say you treat 25 patients a day. I would guess nowadays between Medicare advantage and Medicare and private, about 33% of a rad onc’s workload will be Medicare work. (That’s the only work subject to qui tamming.) So 8 Medicare patients a day. Over a year that will be about 2000 Medicare IGRTs. If you did ALL of them illegally Medicare would reimburse $60K a year for that (come 2026). If you just did them illegally on vacation out of state 2 months a year, that’s just $10K a year.

No one is gonna get qui tammed at these levels of “fraud.”

 

[maxxor]

You do you. This is well established in Radiology billing circles. Even by the language of your post, we agree this is illegal by the laws currently in effect.

 

[TheWallnerus]

You do you. This is well established in Radiology billing circles. Even by the language of your post, we agree this is illegal by the laws currently in effect.

Do not agree it’s illegal. I was tossing the word around in an absurdist kind of way. Illegal is a very strong word. “Settlement” doesn’t equal illegal, but it certainly equals problematic.

There is meager overlap between the rad onc doing IGRT and the radiologist doing diagnostic radiology. There is zero overlap between telerads and the rad onc doing an occasional IGRT sign off off-site. I honestly don’t know of any laws, or even “laws,” that say state lines come into play regarding the latter. But willing to look at them. As we have previously mentioned iirc there truly are laws where country/nation lines come into play.

Whatever any of us think, it doesn’t matter if you have a boss that thinks something different. Like when rad onc went to general supervision in hospitals. I imagine there were many rad oncs who went to their bosses when this changed, showed them the law, and admin was like I don’t care you still have to always be here no matter what… or it’s illegal!

 

[RickyScott]

A lot of us have lived in ny, ct, pa, nj. Very much doubt that igrt 10 miles from your home is illegal. This is Soviet style show me the man, I will show you the crime. It’s even worse than cheating on a diversity module. I am sure we are all breaking law and that’s why we need to retain Ron g to stay out of Jail.

 

[Ray D. Ayshun]

This might be true, but conservative hospital companies will err on the side of easiest, which is to say, they'll not allow it as there is no risk or harm to them. This could be easily solved by having an actual document that says it's okay. One could argue there's a potential liability concern if you're practicing medicine in a state where you're not licensed. Ultimately, this is another example of having a thing we do that's poorly defined and in turn subject to loss because our professional society benefits from losing it

 

[TheWallnerus]

This could be easily solved by having an actual document that says it's okay

Didn’t you quote a document above saying it’s ok

 

[Ray D. Ayshun]

Didn’t you quote a document above saying it’s ok

Kinda. It's nothing official. Also offered was the caveat that you should take into any legal issues that might vary by state. Whoever wrote that said you don't have to list your hotel as the place of service if on vacation. I can't find this anywhere in CMS docs, though, and ASTRO suggests IGRT requires direct supervision.

 

[TheWallnerus]

Kinda. It's nothing official. Also offered was the caveat that you should take into any legal issues that might vary by state. Whoever wrote that said you don't have to list your hotel as the place of service if on vacation. I can't find this anywhere in CMS docs, though, and ASTRO suggests IGRT requires direct supervision.

ASTRO’s suggestions are long in tooth, and toothless, now with all the virtual direct provisos that have been codified in the interim.

 

[Ray D. Ayshun]

ASTRO’s suggestions are long in tooth, and toothless, now with all the virtual direct provisos that have been codified in the interim.

not to hospital admin