See below the reasoning why we have been told to bill with the 26 modifier when the physician assistant sees and reads the images.
The policy is in place because:
1) We do not have actual orders in our system, x-rays are done by verbal orders. If the PA is seeing the patient, they are technically ordering unless ordered by the physician in their dictation prior to.
2) PAs under Medicare, MPB Ch. 80, are not eligible to supervise x-rays done by an x-ray tech. If there is no documentation of physician involvement in the treatment that day then we cant bill the x-ray under the physician.
3) We did try to bill the TC under the physician in some cases, but again, due to no actual order in place, we didnt have documentation to back it up (This is supposedly being addressed by Nick, our IT director)
So the decision was until we have a system in place to be able to provide some actual documentation of the order of the x-ray being ordered by the doctor that it would be billed under the interpreting provider, for some docs, if they are in clinic then they are dictating their own interpretation and we should be billing the x-ray under them. Please forward this to your contact and see what she thinks. This came from an attorney who did a compliance course, If you want to change it you will need to address it with Star and it may need to go back to the doctors.
If the supervising physician is not present to supervise the PA, and the PA is not eligible to supervise the technician who performed it, then what is your suggestion.