Context
A PICC line insertion is performed by a nurse/nurse practitioner and radiographer, including imaging (Fluoroscopy + Digital Subtraction Angiography of thorax). Post examination, a radiologist reviews the images and confirms the positioning and readiness of the PICC line. Noting that the initial catheterisation procedure (13815) cannot be claimed as a nurse performed the procedure, could the radiologist claim for the relevant DSA imaging charge (e.g. 60012)?
Relevant legislative provisions
Health Insurance Act 1973 (HIA)
Health Insurance (Diagnostic Imaging Services Table) Regulations (No. 2) 2020 (Diagnostic Imaging Table Regulations)
Health Insurance (General Medical Services Table) Regulations 2021 (GMS Table Regulations)
Other Relevant Materials
N/A
Case law
N/A
Departmental interpretation
Detailed Reasoning
The starting point is to note that a nurse practitioner does not have billing rights to the relevant MBS items in this scenario, and radiographers do not have Medicare billing rights at all.
In terms of who can claim diagnostic imaging services, the relevant law is copied below.
The questioner is correct insofar as the nurse practitioner cannot claim the PICC line insertion (MBS item 13815), and neither can the radiologist because they did not personally provide the service. Clause 1.2.7 of the GMS Table Regulations lists item 13815 as a service that must be personally performed by the medical practitioner for it to be billed.
It is a permitted usual practice for radiologists to claim the diagnostic imaging services, even though a radiographer or other technician often operates the machine that captures the image. A chest x-ray is a very common example of a diagnostic imaging service performed by a radiographer, but billed by a radiologist. The rationale behind this is that diagnostic imaging services generally have three components which are 1) image capture, 2) analysis and 3) reporting.
In the given scenario the questioner explains that the radiologist reviews and reports the images to ensure the PICC line is in place. These actions will usually enable the radiologist to claim a relevant MBS item, however, there are important requirements that also need to be met before the proposed item 60012 can be claimed, namely:
1. Item 60012 and any of the digital subtraction angiography items in that series can only be claimed if the procedure was performed in an angiography suite. The definition of an angiography suite is above. If a PICC line is inserted in an intensive care unit but claimed as having been inserted in an angiography suite, that would be fraud.
2. In addition to reviewing the films, the radiologist must make an adequate and contemporaneous record detailing their review and clinical findings.
It is unclear whether this hypothetical service is to be provided in an angiography suite or somewhere else, such as an intensive care unit. However, if the service was not provided in an angiography suite item 60012 cannot be claimed. Another item such as 59970 (see departmental notes above) may be appropriate. It is copied below.
The differences between the 60000 series items and item 59970 is fixed machines located in a dedicated angiography suite versus a mobile machine. This is an important distinction to note when allocating the correct MBS item for a radiologist reviewing the films that were captured during a PICC line insertion.
Examples and other relevant information
N/A
Who this applies to
All diagnostic imaging service providers.
When this applies
Always
