Wiki Incident - to billing

[sroyal1031]

I have a question regarding the final rule and remote supervision as it applies to APP supervision and "incident to" billing practices



42 CFR §410.26



Can someone please clarify if remote audio/visual supervision only applies to nurse level visits E/M code 99211. My administrator feels that we are unable to bill for E/M services provided by an APP with remote supervision using incident to rules for codes 99212-99215

 

[Pam Warren]

Telehealth supervision applies anytime supervision is provided, including teaching physician services, ..... but the E&M code (or any code used) has to report services within the scope of the ancillary staff.

For example, nurse visits are only reportable with 99211, as they cannot perform the level of care represented by a higher E&M code. But you can report 99214 for example, if an APP is billing incident-to an MD, and if all other incident-to guidelines are being met (plan of care, no new patients, no new problems, etc.)

 

[sroyal1031]

Telehealth supervision applies anytime supervision is provided, including teaching physician services, ..... but the E&M code (or any code used) has to report services within the scope of the ancillary staff.

For example, nurse visits are only reportable with 99211, as they cannot perform the level of care represented by a higher E&M code. But you can report 99214 for example, if an APP is billing incident-to an MD, and if all other incident-to guidelines are being met (plan of care, no new patients, no new problems, etc.)

Thank you for your response. So the rules didn’t change for an APP to include virtual supervision for incident-to? The supervising MD still need to be within the office of an APP?

 

[Pam Warren]

The provider performing the supervision can be virtual. The MD doesn't have to be in the office if the APP is providing the virtual supervision for the RN. My comments about scope have to do with the service being provided under virtual supervision in the office setting: an integral part of the care currently being provided under the MD or APP, so no new problems and no new patients. And the services being provided have to be within the scope of the practitioner. So an RN cannot provide an office procedure such as a lesion removal, as surgical services are not within an RN scope.

If the APP is performing the incident-to service, then the MD has to be virtually available. Hope this clarifies.