Gastroenterology Coding Alert

Reader Question:

Avoid Confusion Over Billing Physician and NP Services on Same Day

Question: Our NP is working with our gastroenterologist in the same clinic. We are planning to see new patients two days a month. She will have her own visit and cover certain topics with each patient, and our NP will then see the patient on the same day and cover additional topics that she will not be covering. Our NP will mainly cover health maintenance issues.

Are we able to bill for the NP service if it occurs on the same day as the patient sees our gastroenterologist if NP is covering an entirely different subject? The visit with the NP will be 45 minutes and is primarily counseling.

Michigan Subscriber

Answer: When your gastroenterologist and an NP both have a face-to-face encounter with the same patient on the same day, only one bill needs to be sent. The notes of both practitioners can be combined to decide on the level of service and one bill generated under the physician’s name and PIN. In the scenario you describe the combined face-to-face time will exceed 60 minutes for both your gastroenterologist and your NP contacts with the majority of time spent in counseling.Documentation should describe the content of the counseling provided and/or activities to coordinate care.There must be sufficient detail to support the service billed.

So, if time is documented and the medical necessity supports both services, the practice could bill up to a level V service (99205 , Office or other outpatient visit for the evaluation and management of a new patient, which requires these 3 key componentsCounseling and/or coordination of care with other physicians, other qualified health care professionals, or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the presenting problem(s) are of moderate to high severity. Typically, 60 minutes are spent face-to-face with the patient and/or family).

If the total face-to-face time exceeds 90 minutes, then you may add a prolonged services charge (99354, Prolonged service in the office or other outpatient setting requiring direct patient contact beyond the usual service; first hour [List separately in addition to code for office or other outpatient Evaluation and Management service]).

Of course, the practice could also decide to bill the services under the NP’s name and PIN and receive less money. But this generally does not make any sense as your practice will lose out on reimbursement and receive less for services provided by your gastroenterologist.

Remember: The physician and NP must be employees of the same practice. In any shared service, both the physician and the NP must provide their portion of the services face to face. The incident-to rules are all still in effect. You must document medical necessity and what you actually did during the encounter.

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