Primary Care Coding Alert

Hassle-free option: NPP can report the service directly without having to satisfy criteria Your FP won't have to pay back money for nurse practitioner (NP) and physician assistant (PA) services if initial documentation includes an authorizing statement -- or the nonphysician practitioner (NPP) uses her number. Realize Guidance Gone, But Not Dismissed Although CMS rescinded its May incident-to transmittal 87, your best bet may be to incorporate the changes. "I think CMS still intends that physicians must authorize a nurse practitioner or physician assistant to provide follow-up services," says Hugh Aaron, MHA, JD, CPC, CPC-H, at the 2008 American Academy of Professional Coders National Conference in Orlando. The change: For private payers that follow CMS- incident-to coverage requirements, an auditor could request repayment on NPP services when the physician's initial plan of care fails to mention that an NP or PA may provide follow-up care. Check-off 4 Incident-to Service Requirements CMS pays a covered NPP office service billed under a physician's number at 100 percent when the encounter meets these three existing and one new criteria: 1. The NP or PA treats an established problem. An FP with the same tax identification number must first treat the patient for that condition or illness. 2. A physician provides an active role in the continued management of that condition or illness. "CMS has no set time period for how long in between episodes the physician must re-treat the patient for the carrier to still consider the physician's role as active," Aaron says. 3. The physician must provide direct supervision. Although an NP or PA subject to state law may treat a patient without a physician on site, CMS requires a physician be in the office suite to bill a covered office service incident-to the physician, Aaron notes. 4. Now CMS may also require that the physician indicate he approves an NPP provide follow-up services. For instance, if an FP diagnoses a patient with type II controlled diabetes (250.00, Diabetes mellitus without mention of complication; type II or unspecified type, not stated as uncontrolled) and wants the group's NPP to be able to provide medication checks, the FP must authorize this in the initial treatment note. "To cover your incident-to pay, the best bet is for the physician in the initial service to make a brief authorizing statement," Aaron says. Notation could read, "OK to see NPP," he suggests. Example: A physician sees an established patient for a new problem that the FP diagnoses as an upper respiratory infection (URI, for instance 465.8, Acute upper respiratory infections of other multiple or unspecified sites; other multiple sites) and documents a level-three E/M (99213, Office or other outpatient visit for the evaluation and management of [...]