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Petitioner lived in a house located approximately 15-20
miles from the hospital. Petitioner conducted his billing
activities in an office located in the basement of his house.
There was no sign outside petitioners' house indicating that
petitioner maintained his medical office there. Routinely,
petitioner would travel between his house and the hospital two or
three times per day, at least 3 days a week. He employed an
office manager who spent 20 hours per week at his home office.
Petitioner's office manager was responsible for maintaining and
updating patient billing records, assisting patients with
insurance and medicare form preparation, and responding to
questions regarding a patient's bill. Youngcha Kim Chong, a
registered nurse, also was involved in the billing process and
performed the same services as petitioner's office manager.
The billing services that petitioner conducted at his home office
related exclusively to his patients. Petitioner did not provide
billing services for any other physicians.
Petitioner had no other office from which he could conduct
his billing and recordkeeping activities. His patients were
provided with his office telephone number, which was also
petitioners' personal home telephone number. Petitioner's
patients routinely contacted petitioner, or his office manager,
by telephone at his home office for assistance or questions
relating to billing matters. Petitioner rarely treated or
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Last modified: May 25, 2011