APMA News - March/April 2018 - 46

Coverage Corner
By J. Kevin West, Esq.

Your Medicare Number:
When Sharing is Not a Good Idea
With many new doctors joining practices at this
time of year, we frequently hear this question: Can
the new doctor bill his or her services using the
Medicare Provider Transaction Access Number
(PTAN) of the established doctor?
This question is a perennial problem whenever a practice adds a new doctor; it can take an average of three to four months for the new doctor to receive a billing number from Medicare, yet the practice always
wants to have the cash ﬂow and production from the new doctor right away.
Unfortunately, the answer here is a frustrating one: Sharing
is not allowed under these or any other circumstances. Why is
that? Medicare views a practitioner's billing number as "sacred"
to him or her. When a provider submits a claim to Medicare,
the PTAN must be entered on the claim form, and in doing so,

you can find practice
survey data online?
Visit www.apma.org/services
for details.
46 APMA News March/April 2018

J. Kevin West, Esq., is a partner in the Boise, ID, office of Parsons
Behle & Latimer, a regional law firm. He specializes in health-care
law and is PICA's national counsel for Medicare and HIPAA matters. He also is the author of the APMA HIPAA Privacy Manual
and HIPAA Security Manual.
This article is not intended to constitute legal advice or create an attorney-
client relationship, but is intended for general information only. An attorney
or other resource should be consulted regarding individual cases.

For more information, contact the PICA Risk Management department at 800-251-5727, ext. 2107, or visit
www.picagroup.com.

Original thumbs-down graphic by Shutterstock/mrwebhoney.

Did You Know

the provider is saying that he or she personally provided the services reﬂected on the claim form.
The use of another provider's PTAN (or NPI
number) is viewed by Medicare as a misrepresentation of who provided the service, constituting fraud and abuse. In Medicare terminology, the
doctor has submitted a false claim. Improper use or
sharing of a Medicare billing number not only gets the
new doctor in trouble, but the established doctor, as well.
Medicare only allows for billing by credentialed providers
who have completed the lengthy application and background
check. To Medicare's way of thinking, an attempt to bill by an
uncredentialed provider is a serious breach of Medicare rules.
So, what can new practitioners do? When completing the
enrollment application, you will be asked to provide the date
you saw your first Medicare patient at this practice location.
This date will become your effective date if Medicare approves
your application. However, if there are significant errors in the
information provided, leading to the application being denied, you stand the risk of the effective date being delayed and
the services provided prior to this date being denied. Keep in
mind that you have one year from the date of service to submit
the claims for payment.
If the new practitioner is replacing a departing doctor, the
new practitioner can bill under the departing doctor's PTAN
for 60 days under the so-called locum tenens rule.
Bringing on a new practitioner can be frustrating because of
all the red tape. Do not make it worse by making mistakes that
could put your Medicare billing privileges at risk.
n

http://www.apma.org/services http://www.picagroup.com

Table of Contents for the Digital Edition of APMA News - March/April 2018