I’m hoping someone can answer my question or point me in the right direction. I work for a FQHC through Indian Health Services; the facility has made some personnel changes so myself and another co-worker are new to their billing department. Our nurse practitioner provides home visits for some of our home bound elders that live in their own private home or in an apartment complex that is called the Elder Building. We recently discovered the provider is also seeing some of her patients at the Elder Building who do not live there but are being seen out of convenience because they cannot get in to see the provider at the clinic in a timely manner. The provider dictates an office note and bills for the services with a routine office visit code. I told her she couldn’t charge for those services because the patient wasn’t seen at the clinic and that they didn’t meet the guidelines for a home health visit. The provider states it shouldn’t matter because the same entity owns both facilities and she has an office there; I argued that it does make a difference because the place of service that was billed to the insurance wasn’t where the patient was seen. Can someone tell me if this is correct or can the provider continue with seeing her patients there as if they were being seen at the clinic.

Thank you,
Lisa