0108-Facility versus Non-Facility Reimbursement: Incorrect Coding

Dynamic List Information
Dynamic List Data
Issue Name
0108-Facility versus Non-Facility Reimbursement: Incorrect Coding
Review Type
Automated
Provider Type
Professional Services
MAC Jurisdiction
All A/B MACs
Date
2018-10-01
RAC Type
Approved

Description

Under the Medicare Physician Fee schedule (MPFS), some procedures have separate rates for physicians’ services when provided in facility and nonfacility settings. The rate, facility or nonfacility, which a physician service is paid under the MPFS is determined by the Place of service (POS) code that is used to identify the setting where the beneficiary received the face-to-face encounter with the physician, nonphysician practitioner (NPP) or other supplier. In general, the POS code reflects the actual place where the beneficiary receives the face-to-face service and determines whether the facility or nonfacility payment rate is paid.  However, for a service rendered to a patient who is an inpatient of a hospital (POS code 21) or an outpatient of a hospital (POS codes 19 or 22), the facility rate is paid, regardless of where the face-to-face encounter with the beneficiary occurred. Physician services identified by this audit and with a facility/non-facility rate differential will be repriced and may result in an overpayment or underpayment.

Affected Code(s)

All CPT/HCPCS codes with site-of-service differentials

Applicable Policy References

1.    Social Security Act (SSA), Title XVIII- Health Insurance for the Aged and Disabled, Section 1862(a)(1)(A)- Exclusions from Coverage and Medicare as a Secondary Payer
2.    Social Security Act (SSA), Title XVIII- Health Insurance for the Aged and Disabled, Section 1833(e)- Payment of Benefits
3.    42 CFR §405.980- Reopening of Initial Determinations, Redeterminations, Reconsiderations, Decisions, and Reviews, (b)- Timeframes and Requirements for Reopening Initial Determinations and Redeterminations Initiated by a Contractor; and (c)- Timeframes and Requirements for Reopening Initial Determinations and Redeterminations Requested by a Party
4.    42 CFR §405.986- Good Cause for Reopening  
5.    42 CFR §405.929- Post-Payment Review
6.    42 CFR §405.930- Failure to Respond to Additional Documentation Request
7.    Medicare Program Integrity Manual, Chapter 3- Verifying Potential Errors and Taking Corrective Actions, §§3.1- 3.6.6
8.    Medicare Claims Processing Manual Chapter 12- Physician/Non-Physician Practitioners, §20.4.2- - Site of Service Payment Differential