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Medicare Q & A: Summer 2011 Print E-mail
Written by Benjamin L. Frosch   
Wednesday, 03 August 2011 12:59


Q.   We are a diagnostic center (Independent diagnostic testing facility) that has been in business for almost 5 years and will need to revalidate with Medicare provider enrollment in the near future. I heard that Medicare is now charging for revalidation. If this is true, what is the process for submitting payment and what is the cost?

Administrator, IDTF
Miami, FL

A. Effective Friday March 25, 2011, Medicare contractors will begin collecting application fees with certain providers/supplier enrollment applications (both paper and online applications). The application fee is currently $505 for calendar year 2011; however, this fee will vary from year-to-year based on adjustments made pursuant to the Consumer Price index for Urban Areas.

These application fees do not apply to physicians, non-physician practitioners, physician organizations, and non physician organizations. All institutional providers of medical or other items or services or suppliers must pay the application fee. All application fees must be submitted via paper check, until the Centers for Medicare & Medicaid Services (CMS) specifies a mechanism for submitting electronic funds at a future date.

Medicare provider enrollment will not be able to process any CMS applications without the proper application fee having been paid and credited to the United States treasury or an approved hardship exception. If the fee is not submitted, the application will be rejected or billing privileges revoked unless a hardship exception request is subsequently granted. Please refer to for further information. 

Q:  I am a cardiologist that provides interpretation services to an Independent Diagnostic Testing Facility (IDTF).  Specifically, I provide the supervision and interpretation services on the diagnostic center's patients in addition to patients that I refer to the center.  They informed me that because I am their interpreting physician, the IDTF couldn't bill for the interpretation on my own patients.  I was advised that I must bill Medicare Part B directly for the interpretation provided at the diagnostic center on my own patients.  Are they accurate with this information?

Palm Beach County, FL 

A:  According to the Florida Medicare Local Coverage Determination (LCD) policy on IDTF's, when the technical component of a test is performed by the IDTF and the interpreting practitioner is the practitioner who ordered the test, the IDTF cannot bill for the interpretation.   The interpreting practitioner must bill the interpretation since the IDTF cannot bill for the interpretation when the interpreting physician is the referring physician.    You can go to  and refer to the LCD addressing IDTF's for further information.  

Q:  We are an Internal Medicine Practice that moved to a new office about two months ago.   We did the typical things that any business does when they move which includes completing and submitting forwarding address card to the postal service.  Since we moved to our new office, Medicare stopped submitting checks to us.  We called Medicare Customer Service and they advised us that since they were not notified of our new office, they would have to hold our checks until we complete and submit a variety of Medicare documents.  We called Customer Service numerous times and were given different instructions. Can you provide us with advice on how to receive our Medicare checks?  This is hurting our cash flow!

Internal Medicine
Gold Coast, FL

A:  When you relocate to a new office or add an additional location, you are obligated to notify Medicare Provider Enrollment within thirty days.  The US Postal Service will not forward Medicare checks even though you completed the forwarding address card.  The post office returns these checks to Medicare.  

What you need to do is complete a CMS 855B pertaining to this change of information and your new practice location and pay to address.  You also need to complete a CMS 588 EFT (Electronic Funds Transfer) form because Medicare will not mail you any more check after you are caught up.  Medicare now requires that payments be directly deposited into your group's bank account. 

Additionally, you may want to contact Customer Service to find out if you and/or any members of your group need to "revalidate" your PTAN numbers.  Once Medicare Provider Enrollment has processed all of the documents, you will receive all of your back payments in addition to receiving future payments, which will be directly deposited into the group's bank account.           
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 Mr. Frosch is the President of Frosch Medical Consultants, Inc. in Plantation, FL.

Last Updated on Sunday, 14 August 2011 16:57
Medicare Q & A: Spring 2011 Update Print E-mail
Written by Benjamin L. Frosch   
Saturday, 05 March 2011 16:00

Q:   We are a ten person group practice with four partners.  We are in the midst of moving and understand that we must submit a CMS 855B advising Florida Provider Enrollment of our new location.   Our question addresses the signature requirements in section 15.  It states that it needs to be signed by an authorized official, since there are four partners, can any us sign section 15 of the CMS 855B?

Administrator, Orlando

A:    For initial enrollment and revalidation, the certification statement (section 15) must be signed and dated (preferably in blue ink) by an authorized official.  An authorized official is an appointed official to whom the organization has granted legal authority to enroll it in the Medicare program, make changes or updates to the organization's status, and commit the organization to fully abide by the statues, regulations, and the program instructions of the Medicare program. 

            Assuming that all four of the partners are established authorized officials, any of the four can sign.  However, if you are not sure, you may want to check with Florida Medicare Provider Enrollment.  Although there are four partners in your entity, are all four partners enrolled and approved by Medicare as authorized officials? If you find out that there is only one individual partner recognized by Medicare as an authorized official, you may want to consider adding all the partners of the group as authorized officials.


Q: Up until a few weeks ago, I was an employee of a group.  I have decided to leave the group and start my own practice.  My problem is that I do not know my Medicare PTAN, and because of my adversarial departure from the group, they are taking the position that they do not have to give me my Medicare PTAN.  What would be the quickest way for me to obtain my Medicare provider number from Florida Medicare?

Cardiologist, Miami

 A:   The easiest way to obtain your Medicare provider number is if your former employer provides you with the Medicare approval letter which was issued when you joined their group.  That letter would have your Florida PTAN (provider number) and NPI.   Since it sounds like that is not going to happen, you need to send a written request to Medicare Provider Enrollment, PO Box 44021 Jacksonville, FL 32231-4021.  Put in the correspondence your request for the provider number, your legal business name, NPI number, telephone and fax number.  Additionally, since you have left the group it would behoove you to submit a CMS 855R (Reassignment of Benefits) deactivating your relationship with your former employer. 


Q:   The overwhelming majority of our patients are Medicare beneficiaries.  From time-to-time, we have Medicare patients that have other third party insurance and Medicare is their secondary.  My question is how is a Medicare payment determined?

Billing Manager

Gastroenterology Practice, Palm Beach

A:  The Medicare Secondary Payment (MSP) is determined by a series of calculations and comparisons. The primary insurer's claim processing details on their explanation of benefits (EOB) is needed to determine the secondary payment amount.   Three calculations are made per procedure; the lowest of the three is the secondary payment. 

1.) Determine what the Medicare primary payment would be.

  • Note the Medicare allowed amount for the procedure
  • If applicable subtract the Medicare deductible amount applied towards the procedure
  • Multiply the difference by the appropriate percentage:  62.5%, 80%, 85%, or 100% depending on the procedure code and/or provider

2.) Compare the Medicare allowed amount to the primary insurer's allowed amount, select the higher of the two

3.) Subtract the primary insurer's paid amount from the billed amount


Q:  I just opened up my own surgical practice and need some information from Medicare pertaining to global surgery days and the relative units (RVU) for a particular code. Can you direct me to that information?

Surgeon, Broward County           

A: The Centers for Medicare and Medicaid Services (CMS) make that information available on their website.  After you access their website, you need to find the "National Physician Fee Schedule Database Tool".  Click on that icon and you will find all the indicators which will have global surgery days including: pre-op, intra-operative, and post-op days.   You may also access that website by going to, which will direct you to that National Physician Fee Schedule database.

ABOUT THE AUTHOR:  Benjamin L. Frosch is the President of Frosch Medical Consultants, Inc. in Plantation, FL. 
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Last Updated on Sunday, 14 August 2011 16:58
Breaking it down: Analysis of 2011 OIG Work Plan (Medicare Part B) Print E-mail
Written by Benjamin L. Frosch   
Friday, 03 December 2010 11:04


With a few thousand staff members throughout the United States, the Office of Inspector General (OIG) plans and performs audits, investigations, evaluations, and legal activities pertaining to the Department of Health and Human Services (HHS).   With the Issuance of the 2011 OIG Work Plan there are a variety of important Medicare issues that they will evaluate pertaining to Medicare physicians and other health care providers.  This may be a good opportunity to evaluate compliance in your practice with respect to the following Part B subjects that are in the work plan. With a variety of federal agencies looking closer at Medicare fraud and abuse than ever before, it is very clear that there is a zero tolerance for Medicare fraud and abuse. The following is a list of what I think are some of the hottest "subjects" targeted in the 2011 OIG Work Plan:


This is definitely going to be a subject under the microscope in 2011 and beyond.  The OIG is going to review Evaluation and Management (E&M) claims to identify issues in the coding of E&M services. Medicare paid $25 Billion dollars for E&M services in 2009 which represents 19% of all Medicare Part B payments. They will also be reviewing the extent of potentially inappropriate payments for E&M services and the consistency of E&M medical review determinations by Medicare contractors.

Also Medicare contractors throughout the United States have noted an increase in the frequency of medical records with identical documentation across services. The OIG plans to review multiple E&M services for the same providers and beneficiaries to identify electronic health records (EHR) documentation practices associated with potentially improper payments.


The OIG has decided to continue reviewing physician coding of place of service on Medicare Part B claims for services performed in Ambulatory Surgical Centers (ASC) and hospital out-patient departments. Federal regulations provide for different levels of payment to physicians depending on where the services are performed.  Medicare pays a physician a higher amount when a service is performed in a non-facility setting such as a physician office than it does when a service is performed in a hospital outpatient department or, with certain exceptions, in an ASC.  The OIG will continue to evaluate whether physicians properly coded the place of service on claims provided in ASC's and hospital outpatient departments.


As we can all see E&M services are absolutely under the microscope. Under the global surgery fee concept, physicians bill a single fee for all of their services that are usually associated with a surgical procedure and related E&M services provided during the global surgery period. The OIG will evaluate whether medical practices related to the number of E&M services provided during the global surgery period have changed since the global surgery fee concept was developed in 1992.


Diagnostic tests will be under scrutiny in 2011 and beyond.  The OIG will review Medicare payments for high cost diagnostic tests to determine whether they were medically necessary. The Social Security Act provides that Medicare will not pay for items or services that are "not reasonable and necessary". The OIG will address the extent in which the same diagnostic tests are ordered for a beneficiary by primary care physicians and physician specialists for the same treatment.   However, there will be other OIG issues for diagnostic tests. Physicians  are  paid  for services  pursuant  to  the  Medicare  physician  fee  schedule,  which  covers  the major  categories  of  costs,  including  the  physician  professional  cost component,  malpractice  costs,  and  practice  expense.  The  Social  Security Act, §  1848(c)(1)(B),  defines  "practice  expense"  as  the  portion  of  the resources used  in  furnishing  the  service  that  reflects  the general  categories of expenses,  such  as  office  rent, wages  of  personnel,  and  equipment.  Certain imaging services will be under focus with respect to the practice expense components. The OIG will determine whether Medicare  payments  for  Part B Imaging reflect the expenses incurred  and  utilization  rates.   


While there is no doubt that the Florida is a geographic area with a high density of IDTF's, the OIG will be reviewing services and billing patterns in areas such as Florida due to high concentrations of IDTF's.   IDTFs must meet regulatory performance requirements in accordance with 42 CFR to obtain and maintain Medicare billing privileges. In 2006, the OIG concluded that there were numerous problems with IDTF's including non-compliance with Medicare standards and potential improper payments of over $70 million dollars. This issue leads into;


The OIG is going to select certain IDTF'S that are enrolled in Medicare to determine the extent in which they comply with the ITDF Medicare standards. IDTF's received payments of almost $900 million dollars in 2009. Federal regulations require IDTF's to certify on their enrollment application that they comply with the seventeen CMS standards.  Such standards include requirements that IDTF's comply with all federal and state licensure and regulatory requirements that are applicable to the health and safety of patients, provide complete and accurate information on their Medicare enrollment application, and have the appropriate technical staff and physicians who are proficient with respect to the tests they perform.


The OIG will evaluate if outpatient physical therapy services provided by independent therapists are in compliance with Medicare reimbursement regulations and guidelines. Previous OIG work plans have identified claims for therapy services provided by independent physical therapists that were not reasonable, medically necessary, or properly documented.  They will focus on independent therapists who have a high utilization rate for outpatient physical therapy services and will determine whether the services that were billed to Medicare were in accordance with federal requirements.   Florida once again is one of the highest areas in the United States when it comes to providing physical therapy to Medicare beneficiaries compared to the other regions of the country.


There is a concern pertaining to the extent to which clinical laboratories have inappropriately unbundled laboratory profile or panel test to maximize Medicare payments. The OIG will look into whether clinical laboratories have unbundled profile or panel tests by submitting claims for multiple dates of service or by drawing specimens on sequential days.  The OIG will also be looking at trends in laboratory utilization. In 2008, Medicare paid about $7 Billion dollars for clinical laboratory services which represent a 92% increase from 1998.


The OIG is going to take a look at the appropriateness of Medicare payments for sleep test procedures that are provided at sleep disorder clinics. A preliminary OIG review identified improper payments when modifiers are not reported for sleep test procedures. The OIG will examine Medicare payments to physicians and Independent Diagnostic Testing Facilities for sleep test procedures to determine whether they were in accordance with Medicare requirements. 


I think we can all understand why the OIG will take a look at this issue. They plan on reviewing Medicare claims with dates of service after a beneficiary's date of death to assess CMS controls to preclude or identify and recover improper payments. CMS uses several computer database systems that interface with  death  information  on  the  Social  Security  Administration's  and  the  Railroad  Retirement  Board's  systems.  

About the author:  Mr. Frosch is President of FROSCH MEDICAL CONSULTANTS, INC. in Plantation, FL.


Last Updated on Sunday, 14 August 2011 16:58
MEDICARE Q&A: Fall Update Print E-mail
Written by Benjamin L. Frosch   
Wednesday, 22 September 2010 21:40

Q:   I am an Administrator at a Cardiology practice that is purchasing an ultrasound machine and radiology equipment to perform procedures in our office.  We will satisfy the necessary supervision requirements with a non-radiologist, however, we will have a radiologist perform the professional interpretation off-site.  If we hire the radiologist on a part-time basis, will our group practice be allowed to bill Medicare globally for the procedures?  If not, under what circumstances can we bill globally?


Cardiology Practice

A:   There are many issues that have to be considered in your scenario.  If the radiologist is performing the professional interpretation off-site and is a purchased service, the CMS purchase interpretation rules would come into play.  The rules states: an entity that provides diagnostic tests may submit the claim and receive the Part B payment for diagnostic test interpretations which that entity purchases from the independent physician if;

  • The tests are initiated by a physician or medical group which is independent of the person or entity providing the test and of the physician or medical group providing the interpretations;
  • The physician or medical group providing the interpretation does not see the patient; and
  • The purchaser performs the technical component of the test.  The interpreting physician must be enrolled in the Medicare program and no formal reassignment is necessary.
  • The purchaser must keep on file the name, the provider identification number, and the address of the interpreting physician.

The first bullet above states that the test has to be" initiated" by a physician or medical group which is independent of the person or entity providing the test. In simple words, that means if you "ordered" the ultrasound and purchased the interpretation, you would not be able to bill Medicare globally.

With respect to the physician working on a part-time basis in lieu of purchasing the services, you may have an issue with the Stark regulations or even some state laws. The radiologist may be required to provide these interpretations on the site of your practice. You may want to check with a seasoned healthcare attorney to assure that you comply with all of these complex rules, regulations, and guidelines.

Q:  I just received a letter from Medicare informing me of a substantial overpayment. My staff researched this issue and we concluded they are correct with the overpayment determination.  The letter we received states that it is a follow-up letter. I never received the initial notification of an overpayment from Medicare.  My question addresses the interest on this overpayment.  What are the rules on Medicare assessing interest on an overpayment?


Ft. Lauderdale, Fl

A:  Medicare does not charge interest on overpayments that are received within thirty-days.  After the thirty day period, interest is assessed for the first thirty-day period and an additional thirty-day period.  Interest continues to accrue for each subsequent thirty-day period for which payment is not received by Medicare.   When money is offset (withheld from Medicare payments), it is applied to the accrued interest first and then to the principal.   The follow-up overpayment letter probably does not imply you have another thirty-day period to refund the amount nor does it prevent Medicare from withholding future payments after the thirty-day period has elapsed.  If you do not refund the overpayment within forty-days from the date of the initial refund request letter, Medicare may initiate offsets and pursue other efforts of recovery of the indentified overpayment.

The bottom line is, once you receive notification of the overpayment; return the monies as quickly as possible.  The overpayment is considered a debt owed to the United States Government and you can always appeal if you feel that Medicare is incorrect with the allegations of the overpayment or the interest payment.  

Q:  I own and operate a multi-modality Independent Diagnostic Testing Facility (IDTF).   I want to take advantage of the weak real estate market and relocate my facility to a nearby site with better street frontage and other amenities.  My administrator warned me that the move will require recertifying our provider number and may hold up Medicare reimbursements for up to six months.   Is my administrator correct about recertification and could it really delay payments for six months?    


Orlando, FL

A:  In accordance with the Medicare IDTF Standards,  changes in ownership, changes of location, changes in general supervision, and adverse legal action must be reported to Medicare Provider Enrollment within thirty-days of the change.  Should you change your location, it should not delay or hold up your Medicare reimbursement. There is a possibility that you would be required to revalidate, but that is based on other rules. All Medicare providers must revalidate every 5 years. Should you move and be required to revalidate, it would not impact your reimbursement during the process.  Should you submit the proper CMS 855 documents for only change of location, this action would also have no impact on your Medicare reimbursement.

About the author:  Mr. Frosch is the President of Frosch Medical Consultants in Plantation FL

Last Updated on Sunday, 14 August 2011 16:55
The Nine Deadly Sins of Fraud and Abuse in a Physician Practice Print E-mail
Written by Benjamin Frosch   
Sunday, 29 August 2010 12:25

In today's health-care climate, the mere hint of impropriety can lead to investigations and/or sanctions with respect to fraud and abuse. The following are nine "sins" or traps that can put a physician smack in the middle of a government false claims allegation:

1. Continue to take your time and/or ignore billing inquiries by patients or family members.

Don't make this foolish mistake. Take every phone call and inquiry pertaining to billing from patients seriously. Remember, every Medicare beneficiary gets an Explanation of Medicare Benefits (EOMB) that includes toll-free numbers to report allegations of fraud and abuse.

2. Make a foolish decision to "complete" your medical records after you've received an audit notice from Medicare or Medicaid. 

Changing and altering medical records are both illegal and unethical unless you clearly note that the change is an addendum to the original record. Then, at a minimum, record the date you entered this change or added additional information to the medical record.  Clearly make sure that Medicare and or Medicaid is aware of your modification and when it occurred.

3. Rely on information that “Charlene" at Medicare told you.   

Now that you've verbally received billing information from "Charlene" at Medicare customer service, create a paper trail confirming the information. Document the phone call and ask Charlene where you can find the information she advised you was published, i.e., in Medicare websites, Medicare bulletins, or other literature. It's a good idea to document every call you make to Medicare. Include the issue, who you spoke to, the date and time. Do not just take her word for it. Confirm her information before billing Medicare.

4. Permit staff to re-bill all denied services for medical necessity by resubmitting a "covered" ICD-9 code without any documented clinical reason.  

This policy speaks for itself and if caught could become a nightmare. Especially when your billing staff is telling government agents it was your idea.

5. Bill for someone else's services under your provider number without full compliance of the "incident to" provision.  

With respect to physician assistants, nurse practitioners or medical assistants, there is very strict and to-the-point criteria for billing services rendered "incident to" by these individuals under your provider number. Billing hospital visits performed by your PA or ARNP under your provider number is a big no-no. The "incident to" provision was not intended for the hospital setting. If it is a true "shared visit”, the services must be medically necessary.

6. Be proud of your compliance violations. 

Brag in the doctors' lunchroom about billing all of your E&M service as level four and five visits or submitting false diagnoses to get claims paid. Some colleagues within hearing shot may get angry and advise the government of your excellent billing skills.

7. Keep purchasing diagnostic services and marking them up without letting the carrier know. 

This can cause serious problems as Medicare regulation strictly prohibits marking up purchased diagnostic services. Additionally, Medicare issued regulations and guidelines that clearly indicate how the claim is to be submitted. You must indicate on the claim what the cost of the purchased service was (to avoid a mark up), who you purchased the technical component from and meet other requirements. There are also strict rules for billing purchased interpretations. Make sure you comply with all the Medicare rules when billing globally for an interpretation you did not perform 

8. Become a  Medical Director of a  Home Health Agency, Durable Medical equipment Company, or any other Designated Healthcare Service that you refer heavily to.

Make sure you are paid exceptionally well and have no documentation demonstrating your "Medical Director" services. Most important never have seasoned healthcare lawyers review these types of Medical Director relationships or other arrangements.

9. Now that Lebron James, Dwayne Wade, and Chris Bosh are all on the Miami Heat, feel comfortable taking those great (and expensive) Miami Heat playoff tickets from healthcare providers you refer to.

After all, who would ever think that those tickets are related to your referring patients to them? You will just tell the OIG agents that you only refer patients based on "quality" and those tickets would never skew your judgment.


Benjamin Frosch is President of Frosch Medical Consultants, Inc. in Plantation, FL.


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