Altruis Blog

A session includes 15 minutes of therapeutic exercise, 12 minutes of manual therapy, and 8 minutes of gait training. Thirty-five minutes of skilled, billable time. The question is how many units each code earns, and that is where mixed-code billing under the 8-minute rule tends to go wrong.

The rule is simple with one timed activity. It gets complicated with three or four codes and leftover minutes that do not divide evenly. CMS does not want units calculated code by code in the order a clinician happened to document them. It requires providers to:

• Total the minutes across all timed codes on the visit first
• Calculate total billable units from that combined time
• Assign the units to the codes with the greatest number of billed minutes before assigning any to the codes with less time

A staff member who skips that sequence, and assigns units in documentation order instead, can under-bill or over-bill a session without ever triggering a denial. The claim simply pays for fewer units than the visit earned, and nothing on the remittance flags it.

The root cause is arithmetic. CMS's total-time method has to be applied correctly, every session, for every mixed-code visit on the schedule.

FQHCs evaluating a new billing partner often ask about price first and FQHC-specific experience second, if at all. FQHC billing services vary enormously in what they know about encounter-based reimbursement, wrap payments, and HRSA oversight. A vendor that handles general medical billing well can still miss the details that determine whether your health center collects what it is owed.

The variation exists because FQHC billing runs on a different rule set than general medical billing. Your organization operates under Medicare's Prospective Payment System, reconciles Medicaid wrap payments, and answers to HRSA site visit protocols that few billing companies encounter with any other client type.

We’ve compiled the eight questions a CFO should ask when comparing FQHC Billing services.

Your organization outsourced billing to fix a specific set of problems: understaffed positions, rising denials, an AR balance that kept climbing. A year or two later, the monthly report still lands on schedule, but the underlying numbers haven't moved the way you expected. Revenue can underperform for months without a single broken line item to point to.

A provider documents a same-day E/M visit and a minor procedure correctly, but a missing modifier 25 makes the claim look like a duplicate charge. The payer denies it as CO-4, and the twenty minutes of clinical work now costs the billing team another round of research, correction, and resubmission before it generates a dollar.

Revenue is leaving your health center every month through compounding, routine gaps in your billing cycle that individually look manageable but together represent a significant percentage of collectible revenue.