Wiki Incident to question

dwardlow

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While reading an AAPC article https://www.aapc.com/blog/31665-lets-clarify-how-to-keep-incident-to-from-becoming-incident-4
scenario 2 "A physician performs the initial evaluation, develops a diagnosis, and develops the care plan. Auxiliary personnel perform subsequent follow-up services. The physician, however, is not on the premises. Instead, an NP/PA supervises performance of the services by auxiliary personnel.

For this case — even if all other criteria under the incident-to rule were satisfied — the service cannot be legitimately reported under the name/NPI of the NP/PA. The most obvious reason is because the NP/PA did not initiate the care; therefore, the auxiliary person is not performing a service that is integral although incidental to the NP’s/PA’s professional service. As a result, the authority in the coverage rules for NPs/PAs, which are conditioned on compliance with §410.26, would not be satisfied.

Depending on your state, compliance with §410.26 requires that the auxiliary personnel are permitted under applicable licensure rules to perform the service under an NP’s/PA’s supervision. As delegation authority is not commonly found in most NP/PA licensure rules (and where it’s found, it’s extremely limited), it’s possible that such a delegation would not be permissible. As a result, the requirements of §410.26 would not be met."

This hit home to me because I have this situation. 1 coworker states ok to bill with the Dr. NPI as incidental because the PA can't be the supervising physician, and other states because the PA didn't initiate the initial evaluation they are disqualified as supervisor for the auxiliary massage therapist and to write the visit off. Help please...
Dena W. CPB
 
If your state does not allow the PA to be a supervising provider in the absence e of the MD, you cannot use the MD NPI as the rendering/supervising NPI in 24J. You must use the NPI of the provider on site at the time of service. The incident-to rule states the supervising provider may be any provider on site as long as they are in the same specialty of the ordering provider. This was then amended to state that you must also follow any state laws regarding supervision with respect to NPs and PAs.
 
I agree with Debra on this. You do have to bill with the NPI of the provider on site, but as the article states, you will need to know whether or not your state laws allow for the physician to delegate this responsibility to the PA in order to know whether or not it is appropriate to bill if only the PA is supervising. Also, I'd point out that non-government payers may have different policies regarding this so I wouldn't write anything off until your management or compliance officer has had a chance to review this situation. In a case like what you mention above, services of a massage therapist would not likely be covered by most plans anyways, so supervision and 'incident to' requirements might not even apply in this situation. This is something you should work out with input from your practice's compliance or legal resources - As a coder, I wouldn't make an independent decision for something like this.
 
Thank you

Thank you for your input. We only have the 1 provider and 1 P.A.. So if the provider leaves for the day and the P.A. is there still seeing patients using their NPI its all good. But when they toss a monkey wrench in and forget about the massage therapist auxillary personnel that doesn't have a NPI, I was lost. This article pointed out to me (knowing that the insurance plan the patient has will not credential the P.A.) so the incident to rules apply. But we didn't meet them as the supervising physician is not in the building and it states in the article plain as day that the P.A. can bill incident to rules as they are in a different category of phyisician than the auxillary massage therapist, but it didn't say anything about the massage therapist. So I had to ask. I wish we had a compliance officer or a CPC.
Dena
 
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