HCFA presses physicians to declare payment status

Baltimore, MD-Medicare officials are alerting emergency physicians who work for hospital staffing firms and medical groups: You must notify the Health Care Financing Administration (HCFA) of your enrollment in these organizations or risk being in violation of Medicare regulations.

HCFA says it is doing everything it can to get out the word. In recent months, the agency issued a series of letters to group practices in all specialties, including emergency medicine, warning them of the requirement. In addition, the new HCFA provider enrollment forms contain a one-page attachment for use in identifying a physician's status for reimbursement purposes.

The form contains areas for the new physicians to complete in reassigning their Medicare payments to a hospital-based provider in compliance with federal law. Both the physician and the medical group administrator must sign the application before submission.

Furthermore, practitioners who have previously joined contract-staffing firms should submit formal letters to HCFA on their medical groups' stationery acknowledging their relationship to the group. Providers are being advised to follow guidelines contained in section 3060 of the Medicare Carrier Manual in submitting the written correspondence or consult with their local Medicare fiscal intermediary.

"Physicians can have as many reassignments as they want as long as they are legitimate. But we will be looking at cleaning up these reassignment activities," according to a HCFA official who asked not to be identified.

The longstanding reassignment-of-benefits regulation has been a sore point with physicians, who have been routinely billing Medicare through the group practice for their hospital work. According to the regulations, which HCFA was lax in enforcing until about a year ago, medical groups that employ physicians as independent contractors are barred from accepting payments for them.

These physicians must bill directly for their services through a hospital-based entity. Exempted are salaried providers or those who own a partnership stake in the group. About 50% of all emergency physicians presently work as independent contractors.

[For more information about this topic, see The Managed Care Emergency Department, January 1998, p. 3]