Oncology & Hematology Coding Alert

Reader Questions:

Incident-To in a Hospital? Not So Fast

Question: Our office's RN sees an established chemotherapy patient with colon cancer for a checkup. Over the course of a four-minute encounter, the RN:
  conducts a medical examination of the patient, and reviews recent laboratory test results; and
  reviews the patient's pain medication dose, and asks the patient about side effects of pain medication.

How should we code for this visit?


Maryland Subscriber


Answer: In this case, you should report 99211 (Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem[s] are minimal. Typically, 5 minutes are spent performing or supervising these services) incident-to the physician service.

As long as the patient is not new or undergoing a status change, the RN can oversee the visit and the office can use the physician's PIN when filing with Medicare. Also, you would not report code 99211 on the same day the patient has chemotherapy, based on Medicare regulatory guidelines.

Warning: Never report incident-to services in a hospital setting. Incident-to only applies to a physician office practice, and there is nothing called "incident-to" in a hospital, so it does not apply to the hospital setting.

Also, the physician must provide direct supervision for incident-to services. Under incident-to guidelines, the nurse can only perform services set forth in the established treatment plan issued by the physician.

Some payers indicate that anytime a medical decision is made (such as changing the medication), there is no incident-to.

Remember: Incident-to is a Medicare convention and not accepted by all other payers.
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