CMS Pub. 100-02, ch. 13, § 110.1

Dentists, podiatrists, optometrists, and chiropractors are defined as physicians in

Medicare statute, and qualified services furnished by physicians are billable visits in an

RHC or FQHC. These practitioners can provide RHC or FQHC services that are within

their scope of practice and not excluded from coverage (e.g., Medicare coverage of

chiropractic services is limited to manual manipulation of the spine for a demonstrated

subluxation).

An RHC or FQHC can bill for a face-to-face, medically necessary visit furnished by a

dentist, podiatrist, optometrist, or chiropractor if the service furnished is a qualifying visit

for RHCs or FQHCs and all other requirements are met. All services furnished must be

within the state scope of practice for the practitioner, and all HCPCS codes must reflect

the actual services that were furnished.

RHCs and FQHCs are required to primarily provide primary health care. Since dentists,

podiatrists, optometrists, and chiropractors are not considered primary care physicians,

they do not meet the requirements to be either i) a physician medical director or ii) the

physician or non-physician practitioner (NP, PA, or CNM) that must be available at all

times the clinic is open. Therefore, a dentist, podiatrist, optometrist, or chiropractor can

provide a medically necessary, face-to-face visit with an RHC or FQHC patient only

when the statutory and regulatory staffing requirements are otherwise met.

For additional information on these services, see Pub. 100-02, Medicare Benefit Policy

Manual, chapter 15 on Covered Medical and Other Health Service at

http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c15.pdf.