Stark laws deal with referral TO an entity that the physician has a financial interest in. Ancillary services provided IN your own office, as part of the treatment plan, are explicit exceptions to the law. Billing a UDS is fine. Having an MRI scanner in your office is fine. Having PT in your office is fine. Referring only to the stand-alone lab you own for GC confirmation is bad. Referring only to the stand-alone radiology outfit you own is bad. Referring only to the stand-alone PT practice you own is bad.
Thank you. What about DME, mainly the TENS units. I think I'm almost ready to begin prescribing and dispensing but it appears that it's much more complicated than it may first appear with respect to Stark.
So how are you guys billing out for the UDS. What's teh CPT?
Can you bill for the point of care 'cup' test?
Or can you bill for the Ameritox test?
Assuming I'm in a hospital setting. I would think I'm still having to interpret the data although there's no cost to me directly.
This article might help clarify things:
On February 5, 2010, CMS released Transmittal 1905, and thereafter, on March 19,
2010, CMS released Transmittal 653/Change Request 6852 which, when read
together, explain which drug tests can be billed with multiple units of G0431-QW and
which have to be billed as 1 unit of G0430-QW. These Transmittals were
accompanied by a MLN Matters No. 6800 which provides further instructions.
By way of background you may remember that the prior CPT Codes, 80101 (single
drug class) and 80100 (multiple drug classes) were left intact by the AMA, but
Medicare adopted replacements using G0431 (single drug class) and G0430
(multiple drug classes). There was mass confusion due to the wording of the new
codes, and CMS promised, and now has delivered, an explanation which is effective
this Thursday, April 1, 2010.
According to CMS, here are the coding instructions: (1) G0430-QW is to be billed
when multiple drug classes are tested when the testing methodology does not use
the chromatographic method; (2) 80100QW is to be used when testing for multiple
drug classes that do use the chromatographic method; (3) G0431 is to be used per
drug class when performing a test for a single drug class; and (4) Medicare will no
longer recognize 80101.
That still doesnt answer the single cup/multiple dipstick methodology and tell us
which G code is to be used with which test. To respond to that, CMS actually
provided a list of tests which fall under G0430, and which tests fall under G0431.
The tests billable under the 1-unit code, G0430-QW (i.e., where you are limited to 1
unit of G0430 for all drugs tested), are:
Abbott Diagnostics Signify ER Drug Screen Test;
Accu-Stat Drugs of Abuse Home Test for Marijuana (THC) and Cocaine (COC);
Accu-Stat Drugs of Abuse Home Test for Marijuana, Cocaine, Amphetamine,
methamphetamines, Opiates and Phencyclidine;
Accutest Multi-Drug, Multi-Line Screen Test Device;
Acon One Step Multi_drug; Multi Line Screen Test Device (Professional Use);
ADC CLIA Waived Marijuana (THC) and Cocaine Test;
ADC CLIA Waived Multiple Drug Test Card;
Advantage Diagnostics Advantage Marijuana (THC) and Cocaine Home Drug Test;
Advantage Diagnostics Corporation ADC Multiple Drug Test Card;
Alatex Scientific Peace of Mind Multiple Drug Test;
Alfa Scientific Designs, Inc. Instant View Multi-Drug of Abuse Urine Test;
Alpha Scientific Designs, Inc Instant View Multi-Drug of Abuse Urine Cup Test;
Amedica Biotech Amedica Drug Screen Test Cup; American Bio Medica Rapid TOX;
Aventir Biotech LLC Home Check Multiple Drug Test Cup
Aventir Biotech LLC Home Check Multiple Drug Cup Test (Professional Version)
Biotechnostix Rapid Response Multi-Drug, Multi-Line Screen Test Card with
Integrated Cup;
Biotechnostix Rapid Response One Step Multi-Drug, Multi-Line Screen Test Device;
Branan Medical Corporation Fastect II Drug Screen Dipstick Test;
Branan Medical Corporation, Fas Tox Multiple Drug Dipcard;
Branan Medical Corporation, Quick Tox Drug Screen Dipcard;
Branan Medical Corporation ToxCup Drug Screen Cup;
BTNX Inc. Know Multi-Drug One Step Screen Test Panel (Urine);
BTNX Inc. Rapid Response Multi-Drug One Step Screen Test Panel (Urine);
Drug Detection Devices Ltd. Multi-Drug Multi-Line Screeners Dip Drug Test With the
Integrated Screeners AutoSplit KO Test Cup;
First Check Diagnostics First Check Multi Drug Cup;
First Check Diagnostics First Check 12 Drug Test;
Forefront Diagnostics Drugfree @ Home THC/COC Test Kit;
iCassette Multi-Drug, Multi-Line Screen Test Device;
Innovacon Integrated E_Z Split Key Cup II (Professional Use);
Innovacon Multi-Clin Drug Screen Test Device;
Jant Pharmacal Accutest MultiDrug ER11 Drug Screen Test Device;
1 Step Detect Associated DTX Drug Test Cup Integrated E-Z Split Key Cup II;
Phamatech At Home Drug Test (Model 9150T);
Quest Diagnostics Incorporated; Express Results Integrated Multi-Drug Screen Cup
(professional use);
RediScreen Multi-Drug, Multi-line Screen Test Device;
Redwood Toxicology Laboratory Reditest 6 Cassette substance abuse screening
device (Professional Use);
Syntron Bioresearch Quikscreen Multiple Drug Cup Test (Professional version);
Twin Spirit, Inc. Drug Smart Cup;
Wolfe Drug Testing RealityCheck Integrated Specimen Cup;
Worldwide Medical Corporation, First Check Home Drug Test )THX-COC); and
Worldwide Medical Corporation, First Check Home Drug Test (THC COC OPI MET)
The tests billable under the multiple-unit code, G0431-QW (i.e., you can bill 1 unit of
G0431 for each drug tested), are:
Accu-Stat Drugs of Abuse Home Test for Marijuana (THC) Test;
ADC CLIA Waived Marijuana (THC) Test;
DyanGen NicCheck II Test Strips;
First Check Diagnostics LLC,, First Check Home Drug Test Marijuana;
Mossman Associated, Inc. NicCheck I Test Strips;
Phamatech At Home Drug Test (Model 9068);
Phamatech At Home Drug Test (Model 9073);
Phamatech At Home Drug Test (Model 9073T);
Phamatech At Home Drug Test (Model 9078);
Phamatech At Home Drug Test (Model 9078T);
Phamatech At Home Drug Test (Model 9083);
Phamatech At Home Drug Test (Model 9133);
Phamatech Quick Screen One Step Cocaine Screening Test;
Phamatech Quick Screen One Step Methamphetamine Test;
Phamatech Quick Screen One Step Opiate Screening Test;
Phamatech Quick Screen One Step PCP Screening Test; and
Worldwide Medical Corporation, First Check Home Drug Test (THC).
No tests are addressed other than these.
