Wiki Compliance: NP and Physician E/M Service

[Ozbaby]

Per CMS new patient services must be personally performed by a physician with the exception of history obtained by ancillary staff.
If a nurse practitioner sees a new patient in the office to obtain the history and perform an examination but then passes the encounter off to a physician who conducts a pertinent exam (one body system/part) and determine the A/P, does this suffice as “personally performed?”
It is essentially a split/shared service in an outpatient office that is being performed. Does the physician need to do the entire E/M themselves or can the elements be divided between the physician and NP?

 

[Chelle-Lynn]

• In the office setting when the physician performs the E/M service the service must be reported using the physician’s NPI.

• When an E/M service is a shared/split encounter between a physician and a NPP the service is considered to have been performed “incident to” if the requirements for incident to are met and the patient is an established patient.

• If incident to requirements are not met for the shared/split E/M service, the service must be billed under the NPP’s NPI, and payment will be made at the appropriate physician fee schedule payment amount.

So for your scenario you will need to determine if incident to guidelines were met (established plan of care, etc). If yes, ok to bill under the physician. If no, then the account would be billed under the NPP. If the patient is a new patient then incident to would not apply and the claim would be billed under the NPP.

https://www.cms.gov/Regulations-and-.../clm104c12.pdf