ED Coding and Reimbursement Alert

Correctly Report PA Services in the ED:

"Incident To" Does Not Apply

Busy EDs across the country rely heavily on physician assistants (PAs). Under the supervision of a single emergency physician, several PAs can do initial patient workups, procedures, and, in more than 45 states, write prescriptions.

However, confusion over changes in the way PA services are reimbursed by Medicare and a clarification from the Health Care Financing Administration (HCFA) prohibiting the billing of PA/physician services in the hospital setting as incident to resulted in many departments scaling back their use of PAs, not using them altogether, or, in the worst cases, continuing to bill for their services incorrectly.

If hospitals and emergency physician groups learn the requirements for reporting and billing these services and follow a few simple guidelines, EDs can improve their reimbursement and use PAs to improve patient care and satisfaction at the same time.

In order to correctly report PA services, the ED coder must be able to reliably distinguish a PA service from a physician service that is performed with minor assistance from the PA. Knowing the new requirements for reporting services involving PAs to Medicare is also essential.

We spoke to representatives from the American Academy of Physician Assistants (AAPA) in Alexandria, VA, to get advice on how EDs should document and report these services.

Forget Incident To

The main thing emergency departments should be aware of is that the concept of incident to does not apply in the hospital setting, and this includes services provided in outpatient departments like the ED, states Ron Nelson, PA-C, AAPA president and the president and CEO of Health Services Associates in Fremont, MI.

Conversely, in the office and clinic setting, services performed by PAs can be coded as a physician-provided serviceand reported on the HCFA-1500 claim form using the physicians own Medicare provider identification number (PIN)if the following criteria are met:

the physician is on-site at the time of treatment;
the physician originally saw the patient for the first visit to the office or clinic;
and the physician sees the practices established patients for any new medical problems.

In these settings, the PA service is seen as incident to (an integral part of) the physicians overall service to the patient.

In the ED, PAs commonly see patientsparticularly in the fast track and urgent care areaswith the supervising physician remaining available for consultation, and reviewing and signing off on the PAs chart. In some cases, the physician may not review the chart until the end of the shift. Many hospital EDs have been reporting these services as physician-performed services under the incident to provision.

The advantages to this are clearphysician services are reimbursed at 100 percent of the fee schedule by Medicare and most other third-party payers, whereas services designated as PA services are reimbursed at a [...]
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