CMS's Guidelines of "Site Of Service" for Physicians and Providers

Event Information
Product Format
Prerecorded Event
60 Minutes
Product Description

Know the Standards for Selecting the Right Site of Service to Avoid Recoupment and Penalties

It is important to identify the proper “site of service” when performing Medicare services since the location helps dictate the method and amount of payment. These issues become most critical when dealing with physician Part B billing.

Practices may bill by default on CMS 1500 that a physician office is the site of service. However, this may be a misstatement in many instances. There are possible practice locations that may not qualify as an “office”, including for example hospital outpatient departments, hospital based facilities, patient homes, long term care facilities, home health agencies and freestanding clinics. Medicare has recently clarified how to properly identify the site when services are provided in non-traditional location. However, the standards can be confusing.

Choosing the wrong site of service may result in substantial overpayments. Recent cases and settlements indicate that Medicare will seek recoupment and substantial penalties, even exclusion, for what may be an innocent error if it is allowed to continue for a substantial length of time. Further, PPACA and Stark and fraud and abuse law liability can add substantial cost when the wrong service location is chosen.

Join expert Wayne J. Miller, Esq., in this power packed session to get an overview of the standards for choosing the right site of service for physician and other provider services. Wayne will also discuss recent case developments and the liability risk associated with choosing the wrong site.

Topics to be covered include:

  • What is an office for purpose of the site of service rules?
  • What site do you choose: SNFs, HHAs, patient home care?
  • When is a hospital the proper service location?
  • Lessons learned from recent cases
  • How to avoid fraud and abuse and Stark law liability for the wrong selection
  • Impact of the new overpayment rule
  • Site of service basics
  • Defining proper sites
  • Take a look at the problematic POS billing
  • Applying the proper POS code
  • Special cases, e.g., telemedicine
  • Overpayment refund (PPACA)
  • Avoiding liability: waiver via instructions
  • Correcting errors: self disclosure

Who should attend? Hospitals, Physicians, Practice Managers, Medical Groups, Health Care Consultants, Medical Practice and Facility Executives.

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About Our Speaker

Wayne J. Miller - Healthcare Compliance Expert

Wayne J. Miller, Esq., is a founding partner of the Compliance Law Group, Los Angeles, a law firm focused on health care industry legal compliance for clients nationwide. Wayne has practiced healthcare business and regulatory law throughout his 30-year career. His firm represents a wide range of healthcare industry clients throughout the nation. He is a frequent speaker for The Coding Institute national teleconferences on healthcare reimbursement, transactional and regulatory...   More Info
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