When physicians become employees of hospitals or clinics, they often assign their billing rights to the employer as a part of the agreement. Once signed, few physicians give much attention to how the employer codes and bills the services, but the OIG has alerted physicians that could be a big mistake.
The OIG has warned physicians that they remain liable for billing and coding violations by their employer for services billed under the physician’s provider number, even if assigned to the employer. The message to physicians is to “carefully consider” to whom they re-assign billing and to monitor billing practices of the employer or contracted organization. If the organization has a strong culture for squeezing the last nickel out of a bill, physicians are definitely on notice that they are at significant risk if they do not personally review the billing periodically to assure its validity.
Under the Civil Monetary Penalties law, both the physician and the employer/contractor are liable for over-payments from improper billing and face additional penalties of triple damages, $10,000 per false bill penalty, and possible exclusion from Medicare.