Medical billing Service 199A

This is a Medical Billing service providing services for MDs. only. Since medical services are not provided directly to patients the billing service would not be considered a specified service for purposes of section 199A ?

Any thoughts

Wouldn't that be more like an accounting service? Also SSB?

Good point kathyt. Is a medical billing service considered to be a SSB since it is accounting related ?

I read the following on a big 4 web site concerning SSB:

However, the performance of services in the field of accounting does not include payment processing and billing analysis.

From the proposed regs:

For example, the performance of services in the field of health
does not include the operation of health clubs or health spas that provide physical
exercise or conditioning to their customers, payment processing, or research, testing,
and manufacture and/or sales of pharmaceuticals or medical devices.

And from a CPA site (not authoritative):

Additionally, other businesses supporting healthcare professionals such as medical billing services would be excluded from the definition of an SSTB.

thanks HowardS