Can Dieticians Report Obesity Counseling for Medicare Patients?
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Q: I am searching on criteria for obesity counseling (G0447 Face-to-face behavioral counseling for obesity, 15 minutes). Our dietitian attended a seminar at which a consultant advised that dieticians can bill this service for Medicare patients. Can you please clarify and advise?
Bhavna Patel, CPC
A: A dietician may report G0447 to Medicare under carefully defined requirements.
The current, definitive Medicare guide for reporting obesity counseling is MLN Matters® MM7641 Revised (www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM7641.pdf). The article includes counseling requirements, patient eligibility, frequency limitations, and place of service restrictions (i.e., counseling must be furnished in a primary care setting), as well as a list of provider specialty types approved to report the service, including:
01 – General Practice
08 – Family Practice
11 – Internal Medicine
16 – Obstetrics/Gynecology
37 – Pediatric Medicine
38 – Geriatric Medicine
50 – Nurse Practitioner
89 – Certified Clinical Nurse Specialist
97 – Physician Assistant
Per the Centers for Medicare & Medicaid Services (CMS), “If your specialty type is not one of the above, your claim will be denied …”
But the article goes on:
Note: In addition, Medicare may cover behavioral counseling for obesity services when billed by one of the provider specialty types listed above and furnished by auxiliary personnel under the conditions specified under our regulation at 42 CFR Section 410.26(b) (conditions for services and supplies incident to a physician’s professional service) or 42 CFR Section 410.27 (conditions for outpatient hospital services and supplies incident to a physician service).
Bottom line: A dietician may perform obesity counseling, as defined by G0447, and the practice may be paid, if the service is properly documented and billed as incident-to an approved provider’s services in a primary care setting.
Per CMS requirements:
To qualify as “incident to,” services must be part of your patient’s normal course of treatment, during which a physician personally performed an initial service and remains actively involved in the course of treatment. You do not have to be physically present in the patient’s treatment room while these services are provided, but you must provide direct supervision, that is, you must be present in the office suite to render assistance, if necessary. The patient record should document the essential requirements for incident to service. [emphasis in original]
For complete Medicare incident-to billing rules, see MLN Matters® SE0441.