Question Mid-Level billing under Physician's NPI

[Crystal Olson]

The reimbursement is lower if claim is billed under a mid-level. My question is, if the Physician is not in the office, but can be reached by phone, can a Nurse Practitioner or Physician Assistant bill for a new patient visit under the Physician's NPI?

 

[Pam Warren]

No. In an office setting, incident-to rules specifically indicate (for Medicare and other government payers), that a supervising physician must be in the office suite, and that a new patient is not eligible for incident-to billing. Here is the Medicare guidance on this. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.pdf
Read Chapter 60. Now although commercial payers typically follow Medicare guidance, they often don't spell it out in the same way (we just had this discussion yesterday.....), but check your contracts. Overall, it is better to follow Medicare as the source of truth for all payers.

 

[jkyles]

The reimbursement is lower if claim is billed under a mid-level. My question is, if the Physician is not in the office, but can be reached by phone, can a Nurse Practitioner or Physician Assistant bill for a new patient visit under the Physician's NPI?

Please note that even when it is allowed under Medicare's virtual direct supervision waiver the supervising provider must be available by a real-time, two-way, audio and video connection. Medicare intends to make the waiver permanent and allow more services next year, but the connection requirement will not change.

You might be thinking of the permanent telehealth expansion for mental/behavioral/substance abuse treatments that allows the patient to request an audio-only appointment. However, the practice can't require an audio-only appointment and the provider must still have the ability to perform a "complete" telehealth visit during the appointment.

 

[beulastella]

The reimbursement is lower if claim is billed under a mid-level. My question is, if the Physician is not in the office, but can be reached by phone, can a Nurse Practitioner or Physician Assistant bill for a new patient visit under the Physician's NPI?

No, Thats Simple New patient needs examination and Evaluation, through Phone to the NP is just a Guidance and cant be considered as Supervision.