Can a clinic bill for the interpretation of a Computed Tomography (CT) scan?

Billing for CT Scan Interpretation in a Clinic Setting

Yes, a clinic can bill for the interpretation of CT scans, but only when the physician personally performs the complete interpretation and documents it appropriately. 1

Billing Requirements for CT Interpretation

The ability to bill for CT interpretation depends on several key factors:

Who Can Bill

• The physician who personally performs the complete interpretation of the CT scan can bill for this service 1
• The billing physician must certify that "the services shown on this form were personally furnished" or were furnished under their immediate personal supervision 1

Documentation Requirements

• Complete interpretation of all images must be documented
• The interpreting physician must sign the report
• If only a portion of the study is interpreted, billing becomes problematic 1

Billing Codes

• CT colonography uses specific CPT codes (such as 0066T for screening studies and 0067T for diagnostic studies) 1
• No current CPT modifiers appropriately reflect split interpretations by different specialists 1

Common Pitfalls and Legal Considerations

Split Interpretation Issues

• Split interpretations (where different physicians interpret different portions of the same study) create significant billing challenges:
  • Only one physician can bill for the complete interpretation
  • The billing physician must personally furnish all services claimed
  • Billing for partial interpretation may constitute a false claim 1

Risk Management Concerns

• The physician billing for interpretation assumes liability for the entire interpretation
• If using consultants or overreads, clear documentation of roles is essential
• State laws govern how liability is apportioned between physicians 1

Anti-Kickback Considerations

• Arrangements between clinics and radiologists must comply with Federal Anti-kickback Law
• Compensation must be at fair market value and not based on volume or value of referrals 1

Best Practices for Clinic CT Interpretation Billing

Conservative Approach

• Have the clinic physician perform a complete interpretation of all images
• Contract with a radiologist for an overread if needed
• Document that the clinic physician has "personally furnished" all services claimed 1

Employment Arrangements

• Consider employing the radiologist on a part-time basis by the clinic group
• This strengthens the argument that the radiologist has not furnished a designated health service billed by the group 1

Same-Day Hospital Admissions

• If a patient is seen in clinic and then admitted to the hospital on the same day, the clinic visit should not be billed separately
• All E/M services provided by the admitting physician on the same date as admission are considered part of the initial hospital care 2

By following these guidelines, clinics can appropriately bill for CT scan interpretations while minimizing legal and compliance risks.