24828d2e_Compliance_Audits__Answer
[Reference Number] 15 [Topic] DiscretePhysician Billing [Question] Can you speak more to what determines a discretely billed physician? [Answer] 
The issue is not just discretely billed physicians, but private practicing and discretely billed. A physician employed by the provider would not be considered private and the related services would be subject to the surcharge.
Compliance Audits