Wiki Direct Supervision for NP

JRalston

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We have an NP that has started seeing patients on Fridays when her supervising physician is out. CMS guidelines state the supervising physician must be in the office suite in order to bill incident-to services to Medicare. Does this same rule apply to commercial payers as well? I have been unable to find any information on this in the reference materials from our larger commercial payers.

Thanks,
Jennifer Ralston, RHIT, CPC
 
This is a good question. The only feedback that I have been able to get from commercial payers is that they do not recognize NP's and that you should always bill under the supervising physician whether they are on site or not. I don't think there are any concrete guidelines when it comes to billing for NP's as far as the commercial payers are concerned.
 
Jennifer. Not all Commercial carriers follow or not follow CMS guidelines on Incident to Services. I recommend contacting EACH of your commercial payers Provider Rep and ask them individually,

I also recommend you get this in writing. I have had to defend a client of mine in an audit with a commercial payer and incident too services. If the did not have it in writing from the rep that they were told to bill the services under the supervising MD, they would have been faced with a recoupmen of over $600,000.00 in services.

To add to what dlentsch stated, I have seen over the past year to two years that commercial carriers are beginning to credential Nurse Practitioners so it is also best to contact your payers at least annually to check if the guidelines have changed.
 
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