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Incident-to services in Provider Based RHC
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12/28/2020 @ 12:29:00 PM
Post 1 of 3

Contributor: Karen Robinson, Baker Tilly

Can an RHC located inside the hospital's four walls, send their patients to an outpatient area of the hospital to receive injections and infusions and bill the service under the hospital's provider number?  I'm looking for specific CMS guidance on this issue.  Thanks
12/28/2020 @ 12:33:00 PM
Post 2 of 3

Contributor: Patty Harper, InQuiseek Consulting

We will be celebrating Christmas with our family from Dec 23 -28th. I
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Please enjoy this Holiday Season.

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12/28/2020 @ 1:43:00 PM
Post 3 of 3

Contributor: Charles James, North American Healthcare Management Services

I don't think you are going to find specific guidance on this scenario. This needs to be pieced together from what we already know. My first question would be: which injections? Are these all injections which occur incident-to RHC visits? Or are these specialized chemo injections that accompany the infusion services? Referring all incident-to injections to hospital outpatient is problematic for many reasons. Foremost, these are statutorily included in our RHC encounter. In my view referring these to a hospital injection site for separate reimursement would constitute commingling.

For infusions, yes. These are not RHC services in the sense that infusion is not primary care. One would expect the patient to be scheduled separately from their RHC visit.

It is never advisable to hop back and forth over the RHC - HOPD line arbirtrarily. We would NOT advise doing this for all incident-to injections. I hope that helps!

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