Urology Coding Alert

How to turn 'incident-to' services from confusing to profitable. Coding incorrectly for nonphysician practitioner services will cost your practice money - and maybe even attract federal fraud fighters - so your only chance to earn your fair share of reimbursement and to stay out of trouble is to know the "incident-to" rules backwards and forwards.
 
Practices can bill NPP services either as incident-to a physician or under the NPP's own provider number, so practices need to decide which method works best for them. Too many practices reduce this to a simple economic equation. They see that incident-to services are reimbursed at 100 percent of the Physician Fee Schedule and that NPP services get 85 percent. But there's more to it than simple math, experts warn - an incident-to coding misstep is likely to summon auditors to your door.
 
Noting that practices are billing incident-to with increasing frequency, the HHS Office of Inspector General continues to keep nonphysician practitioner services at the top of its watch list.
 
"The biggest problem with incident-to billing is that people aren't aware of the documentation requirement for the supervision component," says Carol Pohlig, BSN, RN, CPC, reimbursement analyst for the University of Pennsylvania. To bill a service incident-to, you need physician supervision from somewhere in the office space. To document this, Pohlig says, you need at least a simple phrase in the progress notes such as "Performed under the supervision of Dr. X" or "Service provided under supervision of Dr. X." It's a relatively simple thing to do, but "a lot of people fail to do that," Pohlig says. New Patients and New Problems Aren't 'Incidental' New patients - and, more important, established patients with new problems - can throw another monkey wrench into the incident-to machine. To bill NPP services incident-to a physician, you must provide the services to an established patient with an established plan of care. If an NPP sees a patient for any other reason, the service must be billed under the NPP's provider number.
 
When practices are especially busy, an NPP will see patient after patient and will bill incident-to the physician because these are patients who have been seen before by the doctor - either today or in the past for the same problem that they're in for today.
 
That's fine, says Emily Hill, PA-C, president of Hill & Associates in Wilmington, N.C. But practices run into trouble when the NPP sees a new patient or a patient who is presenting with a new problem for which he has not seen a physician. When this happens, the NPP can treat the patient but must bill under his own provider number. He cannot bill incident-to the physician for new patients [...]