Billing No-Nos: Diagnostic Testing Global Fees

Many providers offer diagnostic services in-house.  The billing of diagnostic services has two components:  the technical and the professional.  The technical component (TC) is for all non-physician work and includes the administrative, personnel and capital costs of the test.  The professional component (PC) denotes the physician’s work in interpreting the test.  When billing, it’s important to know to which your provider is entitled and to list the appropriate modifier on the claim for proper payment.

Let’s use the example of billing for in-house x-rays in a primary care practitioner’s (PCP) practice.  By conducting the x-ray on the premises with his/her equipment, the PCP is entitled to bill for the TC, which pays for the physical aspects of the test as described above.  If the PCP reviews the images and performs an interpretation, he or she may bill the global fee (technical and professional) as long as the interpretation is documented on the note.  The global fee cannot be billed if the provider only documents that the test was done. 

If the PCP sends the image for interpretation by a radiologist, the radiologist may bill the PC directly to the insurer, using modifier 26, unless he or she is being paid directly by the PCP to interpret the test.  So, the question remains:  if the test is sent to the radio and she is paid by the PCP, can the PCP bill the PC?  The answer is: it depends.

If the radiologist is an employee of the PCP’s practice, then yes, the PCP can bill for the global fee which includes the TC & PC.  If the radiologist is a vendor, external to the practice, the PCP may not bill for the global fee unless he or she performs an interpretation and documents it on the visit note.  In a nutshell, the PCP can’t bill “vicariously” – if you will – for something done by an individual who is not employed by the practice.

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