Practice Management Alert

Warning: Your definition of 'supervising physician' may not match Medicare's

You apply the rules of incident-to billing for nonphysician practitioners all the time, but your take on the rules may be incorrect if you're not aware of a recent CMS statement.

Check out this real-life billing problem and review your knowledge of incident-to rules.

Problem: Our nonphysician practitioners (NPPs) often treat a patient and follow the plan of care of a physician who isn't present in the office. My understanding of incident-to billing is that the supervising physician must have authored the plan of care. Does this mean we simply can't bill for these NPP services?

Answer: Your definition of a supervising physician is incorrect, but you're certainly not alone in making this mistake. Many billers have had trouble interpreting Medicare's rule on supervising physicians, which is why CMS issued a clarification in September to inform billers of the true definition.

The bottom line: Another member of the same physician group can supervise an NPP who is following the plan of care of a physician who isn't present in the office. The supervising physician does not have to be the physician who originally authored the plan of care, says Shannon O. Smith, CRTT, CPC, consultant auditor with Doctors Management in Knoxville, Tenn. Therefore, you can certainly bill for your NPPs' services.

Details: The supervising physician must bill under the same group PIN as the other physician, and must have signed a form 855R reassigning his right to bill to the group. You should identify the supervising physician "in 2310B loop" and list his PIN in REF02 and the IC qualifier in REF01, CMS instructs.
 
When there's no "suite of rooms" in the office, the supervising physician must actually be in the same room as the supervised provider, the transmittal states.

No diagnostic tests: CMS also recently inserted into the manual its new interpretation that providers cannot bill diagnostic tests on an incident-to basis, because these tests have their own benefit category. This interpretation has proved controversial because it means physicians in a group practice can't receive their share of reimbursement for diagnostic tests their NPPs order.