Forgive me for “over explaining” this issue, but it needs some over-explanation. Hyperbaric oxygen therapy (HBOT) is usually provided in either a hospital-based environment or an office-based environment – otherwise known as “place of service” (POS). Different sites of care are identified by two-digit numbers with the doctor’s office being 11 or 49 and the hospital-based site usually being site 22 (or 19, if off-campus). Why does the POS matter?
For many types of medical services (e.g., debridements, evaluation and management services and others), Medicare and most payers reimburse the doctor at a higher rate if the service is provided in the doctor’s office because that means he/she must pay for overhead and supplies, etc. Physician payments are usually less for services provided in the hospital-based setting because the doctor does not have to hire the staff, provide the equipment, or lease the space. If a doctor’s billing organization accidentally puts the wrong site of care on the claim, the doctor could be paid either more or less than they are entitled to. Several years ago, a good friend called me in a panic late one night because he had just discovered that his biller, who claimed she was an expert at wound care billing, had submitted two years of claims under site 11 when in fact, he was working on a hospital-based wound center. That meant that for two years, he had been overpaid for every wound care related service he had provided. The amount of money that he owed back to Medicare was more than $100,000 and it was not sitting in his bank account. It had been spent on his children’s college tuition and his mortgage payments. He was literally hyperventilating over the phone – I am not joking. He had to breathe in a paper bag before we could discuss what he needed to do. Under the False Claims Act (FCA) he had to notify Medicare that he’d been overpaid and work with the government to come up with a repayment plan.
As it turns out, hyperbaric oxygen therapy chamber supervision payments are NOT different between the office-based and the hospital-based setting, so why am I raising the alarm? The reason is that if a doctor is billing the wrong place of service for HBOT, he or she may be billing the wrong place of service for EVERYTHING. This is a particular risk for doctors who work in BOTH the private office setting and the hospital-based setting.
Every year, Medicare posts data on how much they pay physicians under “Open Payments.” Every year, when I look at the CMS payments for hyperbaric chamber supervision (code 99183), I see the names of doctors I know personally who work in hospital-based departments, but their claims are being submitted to Medicare as if they are working in a doctor’s office. One year, I called a couple of them as a friend to suggest that they talk to their billing and they were really mad at me. They said, “How dare I call them about this?” So, I am not calling anyone to tell them. I am just telling everyone who bills hyperbaric chamber supervision that they need to go to this link, go to Export, download the file, and look at column V. If you provide hyperbaric oxygen therapy in a hospital-based setting and you see “O” in column V, your services are being billed incorrectly. This is just an FYI.
Later, I will explain why doctors billing chamber supervision in the wrong site of service is about to cause a HUGE problem for all hyperbaric physicians. But first, see if you are billing correctly.