Wiki NCCI Edit - Provider Edits or Edits per TaxID?

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Hello!
I have been getting different opinions based on my research for this topic.
I cannot find anywhere specifically showing that the NCCI edit manual edits would only apply to the rendering provider NPI.

We have two different providers in one practice (same tax ID, different NPIs) that are doing the following setup:
One physician performs the procedure.
The other physician administers anesthesia for the procedure.

Both providers are capable of anesthesia, both providers are capable of providing the procedure.
But one provider is not doing both at the same time.
Does that make sense?
We want to know if the anesthesia should be unbundled from the procedure since the provider of the procedure was not the provider of anesthesia even though they share the same Tax ID?

We felt both providers should be reimbursed for their services. Are we wrong in that thinking?

Please let me know if you have references to cite! :D

Thank you so much for your help in advance!
~Melissa Rufenbarger, CPC
 
If the providers are of the same specialty, CMS will treat the two providers as if they are the same person for payment purposes. You will find language to this effect in the Medicare Claims Processing Manual and also in the CMS Global Surgery Booklet (link below), where it states that "The global surgical package, also called global surgery, includes all the necessary services normally furnished by a surgeon before, during, and after a procedure. Medicare payment for a surgical procedure includes the pre-operative, intra-operative, and post-operative services routinely performed by the surgeon or by members of the same group with the same specialty. Physicians in the same group practice who are in the same specialty must bill and be paid as though they were a single physician."

https://www.cms.gov/Outreach-and-Ed...ads/GloballSurgery-ICN907166Printfriendly.pdf

If your practice is bypassing NCCI edits by using two physicians to perform procedures that could otherwise be performed by a single physician, your documentation should support the medical necessity of this arrangement and you should be prepared to be able to explain and defend this in writing if questioned or audited.
 
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