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Fraud (PATH audits) (PATH = physicians at teaching hospitals)
- As a general rule, faculty may not bill Medicare for the work of residents.
- Faculty may bill for their own work, and may repeat a resident examination if necessary.
- To appropriately bill under PATH audit guidelines, faculty may make reference to a resident’s history, may simply document the variance between their exam and the resident’s exam, and should document medical decision making.
- Faculty may bill for a procedure if:
- faculty performs the procedure
- faculty was present for the entire procedure
- faculty was present for the key portion of the procedure
- faculty actively assisted the resident in performance of the procedure.
So for the residents, a lot of attendings will want to be present when you do a procedure, not because they think you will need their assistance, but because, procedures are a large revenue stream that can be lost if the attending is not present.
Thanks to Larry Weiss, MD, JD
Disclaimer: This information does not constitute legal advice, is general in nature, and because individual circumstances differ it should not be interpreted as legal advice.The speaker provides this information only for Continuing Medical Education purposes.