Neurosurgery Coding Alert

Reader Question ~ Established Care Plan a Must for Incident-to Billing

Question: If a Medicare patient sees one of our nonphysician practitioners (NPPs) for an E/M service, can we report the service incident-to the physician?

Alaska Subscriber Answer: In some situations, the NPP can bill incident-to the neurosurgeon, meaning that you will receive full reimbursement for the service rather than the 85 percent Medicare pays for NPP services. But the encounter must adhere to specific qualifications before payers will accept incident-to coding:

The NPP must follow an established plan of care. You can bill incident-to only if the NPP is following an established care plan set forth by one of the practice's physicians. Anytime the NPP sees a patient independently, you should bill the service with her unique physician identification number (UPIN) or her national provider identifier (NPI).

The NPP must perform the service under -direct supervision.- To meet -direct supervision- requirements, the physician must be present in the office suite and immediately available to help if necessary.  The neurosurgeon does not have to be physically present in the exam room with the NPP.

Keep in mind, however, that the physician supervising the incident-to service does not necessarily have to be the same physician who authored the patient's care plan.

For example, an NPP treats a patient, and Dr. X is the supervising physician. But the NPP is following Dr. Y's treatment plan, and Dr. Y is not present during the treatment. On the claim, you should report the service incident-to Dr. X because she is the one supervising the NPP's service.
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