Question: I've heard that CMS issued a memorandum regarding new NPP guidelines. Will this affect me? North Carolina Subscriber Answer: The new rules mainly affect billing for hospital visits (e.g., 99221-99223, Initial hospital care), rather than office visits (e.g., 99211-99215, Established patient office visit). Nonphysician practitioners (NPPs) can now bill E/M hospital services incident-to a physician when the NPPinitiates treatment, provided the doctor visits the patient later that day. Transmittal 1776, dated Oct. 25, 2002, states that "when a hospital inpatient/hospital outpatient or emergency department E/M is shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient, the service may be billed under either the physician's or the NPP's unique personal identification number (UPIN)/personal identification number (PIN)." If, however, no face-to-face contact occurs between the doctor and the patient, even if the physician reviews the records, you should bill the service under the NPP's UPIN/PIN. The transmittal reinforces incident-to guidelines, which apply to Medicare Part B providers only. The memo outlines three in-office billing methods: 1. The physician performs the service: Bill the E/M under the doctor's UPIN/PIN. 2. The physician and an NPPshare/split an E/M: If the incident-to requirements are met and the patient is an established patient, bill under the doctor's UPIN/PIN.
3. The physician and an NPP share/split an E/M: If incident-to requirements are not met, the NPP bills the service under his or her personal identification number.
The Medicare Carriers Manual section 2050, available at cms.hhs.gov/ manuals/14_car/3b2049.asp, outlines incident-to requirements. For you to report services incident-to a physician, the service must be:
an integral, although incidental, part of the physician's professional service
commonly rendered without charge or included in the physician's bill
of a type that are commonly furnished in physician's offices or clinics
furnished by the physician or by auxiliary personnel under the physician's direct supervision. Direct supervision encompasses several issues. First, the physician must provide a direct, personal, professional service to initiate the course of treatment. Second, he or she must perform subsequent services of a frequency that reflects his or her continuing active participation in and management of the course of treatment. Third, the physician must be physically present in the same office suite and immediately available to render assistance if that becomes necessary.
Therefore, the transmittal does not offer any way for NPPs to provide initial services to office or clinic patients and reinforces previously held tenants. To view the memo, visit www.cms.hhs.gov/manuals/pm_trans/R1776B3.pdf. The file is in pdf format, which requires Acrobat Reader to open the transmittal. You may download the software at no charge from
www.codinginstitute.com.
