Oncology & Hematology Coding Alert

Just a change in identification and the right documentation and payers will see a higher-paid physician's service when you report nonphysician practitioner (NPP) claims as incident-to. Incident-to is a Medicare reimbursement policy that, under certain circumstances, allows you to report services rendered by NPPs under the supervising physician's number, says Kenneth Lambert, CPC, CCS-P, CPC-H, CCS-P, director of coding/quality services at MMR Management Team in Jacksonville, Fla. The result: You receive reimbursement for those services at 100 percent of Medicare's allowable fee schedule instead of 85 percent of the free schedule allowed under the NPP's number, says Judith Richardson, RN, MSA, CCS-P, a senior consultant with Hill & Associates.

Your incident-to service should reflect this 18 percent increase meaning your NPP should perform a service as if the physician did it, she says. The service must be medically necessary and an "integral, though incidental" part of the physician's professional service. Your practice should commonly render it without charge or include it in the physician's bill, Richardson says.

In addition, the service under incident-to must qualify as one of those your NPP, under state law, can perform. Review your state's licensure and scope-of-practice rules concerning what physician assistants (PAs) and nurse practitioners (NPs) can perform, says Dennis Grindle, CPA, a partner in healthcare consulting at Seim, Johnson, Sestak & Quist LLP in Omaha, Neb. Use these statutes and regulations as your "baseline" for determining incident-to, he says. There's no sense in wasting your time or committing fraud reporting incident-to services your NPP shouldn't be performing anyway. Note that you can also bill for any supplies your NPP may use while performing an incident-to service, he says. When You Should Use Incident-To, 99211 Incident-to is a useful payment method for oncology practices, but 99211 can poison your reimbursement on incident-to claims if you're not careful. NPs, for example, have the qualifications to render many of the services frequently used in patient care, such as nurse assessments, reported as a level-one established patient E/M visit, 99211 (Office or other outpatient visit), and chemotherapy administration for example, 96410 (Chemotherapy administration, intravenous; infusion technique, up to one hour), J9000 (Doxorubicin HCl, 10 mg), J2405 (Injection, ondansetron HCl, per 1 mg) and 90780 (Intravenous infusion for therapy/diagnosis, administered by physician or under direct supervision of physician; up to one hour) if the NPP administered the therapy sequentially to chemotherapy. You may encounter resistance from carriers when reporting 99211 with chemotherapy administration codes. In fact, whether to report 99211 incident-to "is the biggest incident-to issue in the oncology office," says Lynn Anderanin, CPC, senior coding consultant at Healthcare Information Services LLC in the Chicago area. Some payers and practices do not report 99211 for patients who are [...]