Can a physician assistant or nurse practitioner bill for TCM services?

[Quaker]

Does anyone know if a physician assistant or nurse practitioner can bill for a TCM service? If so, does the PA/NP report using their own provider number to Medicare OR do they bill under the MD's number?

 

[SScott10315]

Yes, a NPP (ARNP or PA) can bill for TCM. They would report the services under their NPI as this cannot be billed "incident to" or "shared services". There is a TCM handbook from CMS that is everything TCM. The most recent change in the guidelines is when you can report the service. You can now bill TCM the day it was rendered and only once during the 30 day period and only 1 health care professional can bill TCM services. I have included the link for the 2016 TCM Handbook from MLN.

https://www.cms.gov/Outreach-and-Ed...-Management-Services-Fact-Sheet-ICN908628.pdf

 

[Quaker]

Thanks for your reply SScott.

Can you clarify one more thing for me? The attachment that you provided indicates the following on page 3:

Supervision
"The required face to face visit must be furnished under a minimum of direct supervision and is subject to applicable State Laws..."

I understand that there are certain non face to face services that can be delegated to clinical staff by the MD or NPP, however I did not think that the face to face portion of the visit could be delegated. I presumed that either the MD or the NPP who assumes responsiblility for the TCM service would perform the face to face visit. It doesn't seem to make sense that an MD would bill for the TCM service if the NPP performed the face to face visit and plan of care. It was always my understanding that a TCM service is not appropriate for "incident-to" billing but CMS' statement noted above has confused me.

Can you help clear up my confusion and explain to me what in the world that statement means?

I appreciate your help and time.