The Ins and Outs of Partial Month Billing for the MCP

Sarah Tolson

The Ins and Outs of Partial Month Billing for the MCP

In recent months, I have received many questions with a common theme—billing for a partial month of nephrology services for dialysis patients. In this issue, we will examine these questions and their solutions. The questions keep this column relevant, and I appreciate all of you who read this column and send questions.

Question 1: One of our home dialysis patients dialyzed at home from the 1st through the 12th and was admitted to the hospital for the rest of the month. Can we bill Medicare for the Monthly Capitation Payment (MCP), or do we need to bill the daily code for the 1st through the 12th?

For home dialysis patients, the home dialysis MCP service can be billed to Medicare if the MCP physician had at least one face-to-face outpatient visit with the patient and furnished a complete monthly assessment—even when the patient was in the hospital for part of the month.

Question 2: Last month, one of the home dialysis patients seen in our office had a face-to-face visit with their MCP physician on the 3rd and was admitted to the hospital the morning of the 4th. The patient’s MCP physician saw them twice in the hospital while they were an inpatient, and the patient passed away on the 10th. The patient’s MCP physician didn’t have an opportunity to perform a complete assessment, as the patient was in the hospital. What would be appropriate for the MCP physician to bill in this situation?

Since no complete assessment took place, the MCP physician would bill the age appropriate daily code for the first three days of the month. As the MCP physician saw the patient twice in the hospital, they would also bill the appropriate inpatient evaluation and management code for each encounter with the patient.

Question 3: One of the doctors I work for was responsible for the care of an ESRD patient from out of town who was here to visit their family. My doctor rounded at the dialysis facility where the patient received treatment, and the patient came into our office for a visit while they were in town. The patient was in town from September 20th through October 5th. What would our office bill? What about the patient’s nephrologist in their hometown?

In this scenario the physician responsible for the patient while they were out of town would bill one claim with the age appropriate code for daily ESRD related services for September and one for October, as no complete assessment was given. The MCP physician from the patient’s hometown would bill for the MCP service using the code that reflected the number of face-to-face visits they had with the patient during each partial month, as long as the complete assessment was performed.

In the event a transient patient is under the care of a physician other than their regular MCP physician for an entire month, the physician responsible for the transient ESRD patient would provide the complete assessment and bill for the patient’s ESRD related services under the MCP.

Question 4: On the 20th of last month, the nephrologist whom I bill for was rounding at a dialysis clinic and one of the patients asked if they could transfer their ESRD care to the nephrologist I bill for. The patient’s original MCP physician works for a different nephrology practice. The patient’s care was transferred to our office on the 21st, and they had a complete assessment in our office on the 26th. We billed for the MCP code for one face-to-face visit, but our claim was denied. What would be appropriate for our office to bill in this situation?

Generally, when an ESRD patient changes their MCP physician mid-month, the first MCP physician bills Medicare for the MCP if they have performed a complete assessment, and the new MCP physician bills for the ESRD per day code for the number of days they were responsible for the patient’s care. In the event the first MCP physician does not perform a complete assessment, the new MCP would furnish the complete assessment and bill for the MCP with the appropriate number of face to face visits.

Sarah Tolson is the director of operations for Sceptre Management Solutions, Inc., a company specializing in billing for outpatient ESRD facilities, nephrology practices, and vascular access. Your questions are welcome and she can be reached at, 801.775.8010, or via Sceptre’s website,