Physician Practice

Q&A: You’ve got questions! We’ve got answers!

Physician Practice Insider, March 21, 2017

Submit your questions to Editor Nicole Votta at and we will work with our experts to provide you with the information you need.

Q: In a provider-based department (PBD), when an injection is provided by a registered nurse (RN), is the admin fee billed on the hospital’s UB claim form with the drug or under global billed on the 1500?

A: At a PBD, the nursing staff is employed by the hospital and the supplies used for the injection are provided by the hospital. Additionally, the room, front office staff and other administrative services are provided by the hospital. These services should be billed by the hospital on a hospital UB claim form. The only services that would appear on the 1500 claim form would be the professional services of the physician. Unlike in a freestanding office, the physician cannot bill services incident to their services because incident to billing is not allowed in facility settings. This is because the physician is not incurring costs for the nursing services and supplies, the facility is incurring the costs and should submit the claim for them.

Radiology is a great PBD to illustrate this point, because most of our radiologists are independent. The hospital provides the equipment and the physician provides the professional services. The hospital bills for the radiology technician’s time and the supplies and other facility costs with their facility claim on the UB. The physician would bill for their interpretation only on the 1500 claim. The hospital bill for the injection would be very similar to the hospital bill for the radiology service.

Editor’s note: This question was answered by Kimberly Anderwood Hoy Baker, JD, CPC, director of Medicare and Compliance for HCPro, a division of BLR, in Middleton, Massachusetts. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Opinions expressed are those of the author and do not represent HCPro or ACDIS. Email your questions to Editor Nicole Votta at

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