“My clinic is at the local hospital. I send X-rays to the radiology department. They are eventually read by a radiologist. However, I actually evaluate the x-rays and interpret them myself. Can I bill that component of the radiology fee? And if I do, will it affect radiologist reimbursement?”
If a podiatrist has a private practice and obtains his or her own X-rays, the global reimbursement for the X-ray studies can be billed. The global package includes both the technical and the professional components of the X-rays that were obtained. The technical component is for the obtaining and the processing of the X-rays. The professional component is for the interpretation of the X-rays and the generation of an X-ray report. How are they billed? With the assumption being that 3 views of the right foot were obtained, the global X-ray package is billed in the following fashion: CPT 73630 – RT
In a setting as described in the above post where the provider’s clinic is at the local hospital, the billing for X-ray studies takes a different turn. The technical and professional components of the X-rays that were performed are billed individually. The technical component is billed by the party that owns the equipment, in this situation the hospital. The professional component is usually billed by the radiologist or the radiology group that has contracted with the hospital to interpret the radiological studies that are obtained. How are they billed?
With the assumption being that 3 views of the right foot were obtained, the technical component is billed in the following fashion:
CPT 73630 – RT, TC
TC TECHNICAL COMPONENT ONLY: Use this Medicare modifier when you are only billing for the technical component of a service such as X-rays.
The professional component is billed in the following fashion:
CPT 73630 – RT, 26
26 PROFESSIONAL COMPONENT ONLY: Use this modifier when you are only billing for the physician component of a service such as X-rays.
When the global reimbursement of X-rays is broken down into its components, the technical component comprises approximately 2/3 of the reimbursement and the professional component comprises approximately 1/3 of the reimbursement.
As a rule, a set of X-rays can only be read, interpreted and billed for one time. Therefore, whoever submits the claim first obtains the reimbursement. In the above post, this can be problematic. In a facility setting such as a hospital as described above, it is expected that the radiologist will receive the studies, interpret them, generate a report, submit a claim and be reimbursed. It is fine if the podiatrist “evaluates the X-rays and interprets them himself.” However, if the podiatrist submits a claim for the professional component of the X-rays before the radiologist does, the podiatrist will receive the reimbursement, not the radiologist.
Of interest is the fact that if the podiatrist reviews the X-rays that were obtained and generates his or her own report of the findings, this can actually enhance the level of E/M service that is billed at the next patient encounter for the issue that the X-rays were obtained. Based upon the fact that the podiatrist ordered the X-rays to be obtained and reviewed the results of the X-rays that were obtained and interpreted by the radiologist and documented the findings in the medical record, this creates a “Limited Amount and/or Complexity of Data to be Reviewed and Analyzed. When performed in combination with either a Low Number and Complexity of Problems Addressed or a Low risk of morbidity from additional diagnostic testing or treatment, this will generate a Low Level of Medical Decision Making for this encounter which leads to a Level 3 E/M service (ie. 99213) which reimburses far more than the professional component for the X-rays that were obtained.
This is my opinion.
Michael G. Warshaw
DPM, CPC
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