Billing for IBT for Obesity by a PA or NP

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I'm having a discussion with a billing friend of mine about whether a NP can bill for IBT for obesity (G0447 or G0473) using her own NPI and working in a cardiologists office. The NP falls in the specialty code 50, taxonomy 363LP2300X, Physician Assistants & Advanced Practice Nursing Providers/Nurse Practitioner, Primary Care and the cardiologists office is a POS 11.

Looking at MLN Matters® Number: MM7641 - IBT for obesity, page 5, it looks the services performed by the NP would be covered.

My friend says no because the NP is not working in a clinic of an internal medicine or family practice.

Any thoughts? Comments?
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The NCD states "... counseling is furnished by a qualified primary care physician or other primary care practitioner and in a primary care setting."

"For the purposes of this decision memorandum, a primary care setting is defined as one in which there is provision of integrated, accessible health care services by clinicians who are accountable for addressing a large majority of personal health care needs, developing a sustained partnership with patients, and practicing in the context of family and community. Emergency departments, inpatient hospital settings, ambulatory surgical centers, independent diagnostic testing facilities, skilled nursing facilities, inpatient rehabilitation facilities and hospices are not considered primary care settings under this definition."

"Physician Defined.—For purposes of this paragraph, the term “physician” means a physician described in section 1861(r)(1) and the term “primary care physician” means a physician who is identified in the available data as a general practitioner, family practice practitioner, general internist, or obstetrician or gynecologist."

"Primary care practitioner—The term “primary care practitioner” means an individual— (i) who—
(I) is a physician (as described in section 1861(r)(1)) who has a primary specialty designation of family medicine, internal medicine, geriatric medicine, or pediatric medicine; or
(II) is a nurse practitioner, clinical nurse specialist, or physician assistant (as those terms are defined in section 1861(aa)(5))."

Specialty codes would have to be 50 for an NP and 97 for a PA. The POS of 11 is covered.

However, somewhat like your friend, I'm on the fence about the "primary care setting" and it being a cardiologist's office. The way the policy describes a primary care setting doesn't explicitly exclude the cardiologist's office; but in my opinion, I don't think the specialty of that office is broad enough to meet the criteria, such as "addressing a large majority of personal health care needs." I see it as, a cardiologist's office addresses a large majority of cardiology-related health care needs; and "personal health care needs" reads to me like a wide array of problems, not restricted to one specialty. In the end, everything is good to go, with the exception of the specialty office in my eyes.