Merging practice podiatry into Ortho, can I bill my prior patients as new vs established?
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In the context of your practice’s merger and the new Tax Identification Number (TIN), it’s important to understand how Medicare defines “new” and “established” patients for billing purposes. According to the Centers for Medicare & Medicaid Services (CMS), a new patient is one who has not received any professional services—such as Evaluation and Management (E/M) services or other face-to-face services—from the physician or another physician of the same specialty within the same group practice in the past three years.
This definition hinges on the National Provider Identifier (NPI) rather than the TIN. Therefore, even though your practice is adopting a new TIN due to the merger, patients previously seen by you or another podiatrist in your group within the last three years are considered established patients. Billing them as new patients solely based on the new TIN would not align with Medicare’s guidelines.
However, if these patients are now consulting with an orthopedic specialist in your merged practice and have not seen an orthopedic specialist within the same group in the past three years, they may be classified as new patients for that specialty. This distinction is based on the specialty of the provider rendering the service.