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diagnostic interpretations
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1/7/2021 @ 4:20:00 PM
Post 1 of 3

Contributor: Karen Robinson, Baker Tilly

If an RHC contracts with a radiologist to interpret xrays performed in the RHC, can the contracted radiologist bill Medicare directly or must the interpretation be included in the AIR?  if included in the AIR, is this service reported on the RHC qualifying visit claim?  
1/7/2021 @ 4:43:00 PM
Post 2 of 3

Contributor: Patty Harper, InQuiseek Consulting

If the costs to engage the radiologist are included in allowable costs, then the interpretation is reported on the RHC claim and is included in the AIR. If the RHC doesn't contract with the radiologist and no costs are passed through as RHC allowable costs, then the radiologist should be able to bill independently. This is one of those questions for which CMS has given us different answers. It all depends on if the cost of contracting or compensating the radiologist is included in the allowable expenses or not. If they are in the RHC costs, then they are already in the AIR and would not be billed separately.

Patty Harper, RHIA, CHTS-IM, CHTS-PW, CHCR
Healthcare Consultant/Principal
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1/7/2021 @ 4:56:00 PM
Post 3 of 3

Contributor: Karen Robinson, Baker Tilly

Thank you Patty, would the same concept apply to EKG interpretations?  I'm thinking of a provider-based RHC where a doctor outside the RHC performs the EKG interp.

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