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APP is billing provider of recordNP or PA on-site at RFC submits claim under their NPI, linked to RHC CCN. LC physician is consult only — never the billing provider.
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APP physically present 50%+ of hoursRHC requires NP/PA on-site for at least half of all operating hours. This model satisfies that requirement.
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APP is W-2 employee at RFCCannot use contracted or agency staff to satisfy this requirement. Must be direct employment at RHC site.
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51% primary care visitsAt least 51% of all RFC encounters must be for primary care. Specialty-only pivot voids RHC status.
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Location grandfathering — verify annuallyIf RFC's area loses HPSA/MUA designation, clinic must remain at this physical address to retain grandfathered status. Relocation = re-certification.
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CHOW — inherited liability riskLC accepts RFC's full Medicare history on assignment. Pre-acquisition audit of overpayments and compliance gaps is critical before closing.
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Never code as distant-site telehealthIf the LC physician is listed as billing provider for RFC visits, CMS pays ~$98 telehealth rate — not the AIR. The app workflow must prevent this routing error.
