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FQHC Billing Question : non fetal stress test

According to CMS regulations, under Chapter 13 in the Medicare Benefit Policy Manual, 60.1, would fetal non-stress tests performed in the office setting fall under Incidental and Integral part of physician’s professional services, making it necessary for the physician to be on site in order to bill for the service?

In short, don’t think so.   CMS recognizes three levels of supervision: general, direct, and personal. General supervision means the billing.provider does not even need to be on-site; e.g., lab, ultrasound.  Direct means the billing provider needs to be in the office suite “within shouting distance;” e.g., residency supervision or “incident to” billing. Personal supervision means in the exam room with the patient; e.g., personal oversight of surgical resident if wanting to bill as attending. Thinking fetal stress testing (like ultrasound) falls under “general supervision” not requiring physical presence of the billing doctor.  

With exception of SSI patients, questioning how many OB services are rendered to Medicare patients.  Can research whether fetal stress tests definitely fall under “general” supervision, or not, if desired.

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