Pediatric Coding Alert

Incident-to creates off-site hang-upsDon't let your staff attend school conferences unless they can bill independently, or your practice will be left footing the bill.With the creation of the new nonphysician team conference codes, Pediatric Coding Alert "offered the 'idea' to have a nurse attend an off-site IEP in place of the physician," says Jen Krohn, CPC, CCP, coding specialist, at Waukesha Health Care Inc.-in Wisconsin. Unfortunately, the suggestion comes with a snag: What code and what name would you bill the service under, and would it have to meet incident-to guidelines? Krohn asks.This instructional education program (IEP) code hang-up calls for an incident-to primer.Opt for NPI if AvailableFor a nonphysician to directly report a service, she must have a national provider identifier (NPI). Not all nonphysicians are eligible for an NPI. "A nurse (RN) or respiratory therapist (RT) cannot bill a service under her NPI because she is not eligible to have one," says Richard H. Tuck, MD, FAAP, a pediatrician at PrimeCare of Southeastern Ohio in Zanesville.Option: You would instead have to have an NPI- credentialed nonphysician attend an off-site IEP. For instance, Medicare allows nurse practitioners to register for an NPI.Example: A nurse practitioner who has an NPI attends an off-site IEP in lieu of a pediatrician. The nurse practitioner should report the nonphysician team conference code under her NPI.For a team conference that the parent(s) and/or patient attend, the nurse practitioner would report 99366 (Medical team conference with interdisciplinary team of healthcare professionals, face-to-face with patient and/or family, 30 minutes or more, participation by nonphysician qualified healthcare professional). If the patient and/or family does not attend, she would report 99368 (... patient and/or family not present ...).Reserve Incident-to for Direct SupervisionNonphysicians who are restricted from NPI status may report their services incident-to the physician -- if the encounter meets certain criteria. "Medicare incident-to rules require 'direct physician supervision,' " says Becky Dolan, health policy analyst with the American Academy of Pediatrics (AAP). In the case of an off-site team conference that a nonphysician provides when the physician is in the office, there is no direct supervision, she says.Reporting the off-site service using the physician's NPI would incorrectly imply that either the pediatrician provided the service or a nonphysician performed it incident-to. (Remember: Incident-to services are blind on a claim -- there is no way to label them as nonphysician- performed.) Because the physician did not provide direct supervision, the service would not meet incident-to criteria, making this method improper.Realize NPI Entry Causes GlitchIncident-to is a Medicare concept. CPT contains no language indicating that direct supervision is necessary when reporting a team conference code, Tuck says. Nor does CPT restrict team conferences to an office setting.If a payer [...]