Maybe 40 years ago only MD doctors were qualified to perform medical procedures and thus to have NPI's, but things change. Now states are all over the place on

Maybe 40 years ago only MD doctors were qualified to perform medical procedures and thus to have NPI's, but things change. Now states are all over the place on what professional is qualified to provide what service. Most states probably require some kind of registration, but I also wouldn't be shocked to learn some ancillary physical therapy or acupuncture or chiropractic service can be billed somewhere by someone who only has a PhD. Not in Texas apparently, but somewhere. The article was about a brazen 'slam dunk' fraud, but for the 99% of other schemes that inflate a bill 5%, 10%, 15%, the blame is laid more correctly at the feet of the AMA and it's CPT Codebook (the 99215 in the article) which at once makes billing for things an awful chore and makes prosecuting less brazen schemes a total headache. Look up 99215, for example. First of all, the description is copyrighted IP not freely available for use. Second, if you find it, it's a timed procedure that doesn't have a specific time attached to it. Just proving 'you billed for a long examination and didn't actually spend much time with the patient' generally will not suffice to prove fraud. Instead you need to delve into medical notes, interviews and compare the lengths of other examinations, just to demonstrate falsity for one occasion, one exam. This, and all the secrecy attached to medical records, is a big reason why medical billing anomalies are so unlikely to generate legal department responses.