May 24, 2011



I work for a hospital. We bill for Physician services provided inside the hospital (in and outpatient) and also we bill for physician services provided in a few satellite clinics that the hospital own, and recently the hospital purchase a Doctor Private practice

My question is the following:

What or who determines if the services in those clinics are being billed as an office or as a clinic (out-patient hospital)? i.e. depends on how they are set up? Depends who is carrying the cost to provide the services? ( In some cases the providers receive a salary from the hospital, in some other the Providers are in a PC..

Also can you bill one insurance one way (meaning out-patient hospital (place of service 22), and another insurance as an office (place of service 11) for the services provided at the same location?

This is one example:

Patient goes to see the doc in one of the "satellite clinics, offices". Patient receives an injection. The "clinic/office" will bill for that the drug itself and the administration. The drug itself is being provided by the Hospital's Pharmacy. Later the cost for drugs are being "deducted" from the clinic's budget...

Thank you in advance for your help.



CC, tough question and depending on who you ask and their specialty (atty, biller, coder, acct), I bet you get a few different answers. My general answer, as I do not have enough information to comment specifically on your particular arrangement, is the billing for a particular service must be by the Tax ID of the entity under which the services are provided. To determine which entity the services are provided by, I would look towards the written contracts in place (because, of course, we have written contracts in place, as they are required), and I would get down to the meat of things and determine who works where. The entity the practitioner is associated with for whom you are billing is the entity that should be reflected by Tax ID number on any HCFA. Also, the practitioner actually rendering services should be indicated where appropriate.

To use your example, the professional services rendered by a practitioner at the satellite clinic for the injection received by the patient - the cost of the drug and professional administration - should be billed under the clinic. The Hospital's Pharmacy is not providing the drug for free, so it follows the Hospital would have to be compensated and why not through a deduction/pass-through of the expense of the cost of the drug - through overhead.

To address the site of service - 22 v 11 - the language that I am familiar with allows the use of 22 only where an article 28 licensed facility is in play - and excepts out that code by use of a physician practice. I don't see how you can use those codes interchangeably. It sounds as though the many entities in the same location seem to be blurring the line as to appropriate operational standards. I recommend sorting out the arrangement to clarify who is doing what on behalf of whom before a (or many) payors identify a lack of consistency and potential error(s).

If you require a more thorough answer, please do not hesitate to contact me. I would be happy to work on the arrangement and ensure you are structured correctly.


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