Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
to both physicians and patients because physicians gain
flexibility to establish the most appropriate employment or
contractual relationships for their lives and lifestyles
and patients benefit by having medical services combined on
one bill, which avoids confusion and additional paperwork.
A commenter opposed to direct billing stated that, with
respect to the situation in which multiple supplier are
engaged in the treatment of a patient, a prohibition on
reassignment would force suppliers to bill Medicare
directly only for the services provided directly by each
supplier, resulting in a doubling of the claims that are
submitted, with an increase in billing expenses. The
commenter asserted that this prohibition would also be a
concern for locum tenens physicians who are, by agency
definition, independent contractors. According to the
commenter, it does not have the infrastructure to submit
and collect payments from Medicare, and thus its contracts
are based on the ability to reassign its Medicare claims to
the physician or practice it is supporting.
Some commenters were in favor of direct billing,
stating that itemized billing encourages transparency
relative to the amounts paid for the TC and PC of tests
ordered by the billing physician or group. The commenters
stated that an itemized bill would identify the PC and TC
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