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In this case, the DME is dispensed in the office to a patient, the provider was employed by their medical group (W-2), so does the employed provider's name go in box 31 or the group DME name?

To answer this question, one needs to know which nerve block code(s) you are intending to use. Some such as 64450 (injection into peripheral nerve) , do not have an imaging section within their narrative and also do not have an NCCI edit precluding performing the diagnostic guidance (76942) . Others such as 64445 INJECTION(S), ANESTHETIC AGENT(S) AND/OR STEROID; SCIATIC NERVE, INCLUDING IMAGING GUIDANCE, WHEN PERFORMED, which is typically used by anesthesiologists pre or post operative pain or pain managment physicians for pain relief, have as noted an imaging guidance within their narrative and also an NCCI edit precluding its use. The CPT book also precluedes the narrative. For Morton's neuroma injections (64455) there is no narrative preclusion, however interestingly enough there is an NCCI edit precluding billing 64455 with 76000 (fluroscopy) and both ultrasound follow up (76970) and 76998 (ultrasound guidance intraoperative). There is no preclusion from billing the Morton's neuroma injection with 76942 (diagnostic guidance). However, the latter 76942 would be inappropriate if the diagnosis has already been confirmed either clinically (alone) or with diagnostic imaging. The last issue to consider is the medical necessity for use of any guidance technique in particular for injections into superficial tissue structures which can easily be palpated.

This question can apply to just about any procedure in any MAC. Podiatrists are considered physicians under Medicare, but only as it applies to their state scope of practice. That is, podiatrists may be able to perform one procedure (e.g. a gastrocnemius resection) in one state but not another, this regardless of their level of training. The podiatrists (or any physicians) scope of practice or degree (DPM/MD/DO) is not the only limiting factor regarding the performance of specific procedures. The LCD (if one exists) for given procedures may not specifically preclude reimbursement based on the practitioner's degree. However LCD may require the practitioner to have certain credentials, which would be imposssible for a DPM to obtain. For example, the LCD covering reimbursement for NCV in certain states requires the practitioner to be board certified in either Physical Medicine and Rehabilitation or by the American Board of Neurology. This effectively precluding DPMs from performing and certainly billing for NCV testing. Thus the questioner is correct in that the scope of practice may address the legality of the podiatrist being able to perform endovenous ablation. In the state of Florida, there are in fact numerous podiatrists who are performing such procedures, as is their right based on scope of practice. The next question to research is whether or not First Coast Medicare (the Florida MAC) has any reimbursement restrictions. The Billing and Coding: Treatment of Chronic Venous Insufficiency of the Lower Extremities contains ICD10, CPT and conservative therapy restrictions which must be met prior to First Coast covering such proecdures. There are however, no licensure or credentialing limitations. In the peformance of further research there is the following in an LCD "Response to Comments: Treatment of Chronic Venous Insufficiency of the Lower Extremities: A comment was received to include non-physician licensed independent providers (nurse practitioners and physician assistants) to those who are allowed to perform procedures covered within the LCD. The response while not directly answering whether podiatrists can perform endovenous ablation (as DPM's are considered physicians under Medicare) was answered this way: "We appreciate your comment. Provider types and provider qualifications are not included within the LCD. It is the responsibility of the provider to comply with all applicable State and Federal laws related to the human use of agents." That being said, if you are going to perform such procedures you will be held to the same standards of documentation and performance as any one else (e.g. board certified vascular surgeon) performing such procedures. As for non Fee for Service Medicare Carriers, including Medicare Advantage Carriers and others, they may have exclusions which go beyond First Coast as is their entitlement under Federal and or State law.