The May 5 1998 issue of ” AOPA IN ADVANCE” has indicated that a device
is not considered complete and can not be billed untill all appropriate
componetry is given to the patient to keep. An example of a prosthesis
without a cover being delivered to a patient in the hospital is then
sited. HCFA does not consider this complete and therefore can not be
billed by the hospital.
While this policy may work well to circumvent the new PPS regulations
relative to SNF’s it, in my opinion, does not help when dealing with
Medicare patients who do not reside in SNF’s or are hospital in
patients. This type of patient happens to be the bulk of our patient
load. Also other third party entities tend to follow HCFA regs.
I don’t see any reason why we can not use seqential billing practices.
We incur a great deal of up front costs in materials and especially
labor. Should componetry change during the fitting process (ie:change
from safety knee to hydraulics)the new componet can be billed with a
modifier for a reduced charge to take into accoun the initial cost of
the safety knee. Additionally we commonly allow the patient to use the
prosthesis on a trial basis with a one week follow-up appointment prior
to final finishing. Curently we have a patient who has not kept their
last two appointments. Meanwhile we are not allowed to bill for our
services that have been provided up until this point. As the profit
margins decrease cash flow becomes even more important than it ever has
been. I believe this policy will increase our A/R significantly.
I would like to know if anybody feels this an issue that AOPA should
pursue further with HCFA. Kathy Dodson tells me that she is more than
willing to do this but would like to have further input from the field.
I will be more than happy to recieve your comments and forward them on
to her. Thanks for your time and thoughts.
Brian L. Gustin C.P.
