In some cases, physicians had been allowed to reassign their benefits to entities that were not eligible to receive Medicare payments. The law allows Medicare to pay someone other than the provider of service or supplier in certain circumstances and if certain conditions are met. An employer relationship exists is evidenced by the issuance of a Form W-2. Medicare benefits for covered physician or supplier services furnished in a facility may be paid to the facility under assignment if the facility and the physician have entered into an agreement under which only the facility may bill and receive fees. The Medicare program may pay the facility in which the service was furnished if there is a contractual arrangement between the facility and the physician or other supplier under which the facility bills for the physician's or other supplier's service.
Payment is to a health care delivery system.
HCFA's requirements are discussed in section 3060.3 C of the Medicare Carriers Manual. Basically, in order to be considered a health care delivery system, an organization must be either a clinic, carrier dealing prepayment organization, a direct dealing health care prepayment plan, or a direct dealing HMO or competitive medical plan. For payment to be made to a clinic for physician services, the services must be furnished within the physical premises of the clinic. This plan will require the organization to establish acceptable payment arrangements where the Medicare payments are sent to the physician or the facility or clinic. The physician may be asked to complete a new enrollment form.