Wiki Non-physician provider signatures


True Blue
Rensselaer, NY
Best answers
While doing coding reviews, I have discovered that all claims for services by our non-physician providers (NPs, PAs and CNMs), regardless of who the payer is or type of service rendered, have the claims signed by a physician. In some cases, all the progress notes are also signed by the physician. We will set aside Medicare claims for another audit of incident to, but my question is to the others. Are there regulations for signing progress notes? I can't find anything other than incident to rules. This is making me think that internal policies dictate this practice. Does anyone else have physicians sign for NPP's, especially progress notes? If so, what is the basis and your documentation?

Thank you.
In our large group, the supervising physician signs all documentation. The incident to rules (which is only recognized by Medicare) is in relation to the 100% reimbursement rather than the 85% reimbursement.
Internal policy?

Donna, is that an internal policy for your organization? Since I can't seem to find anything other than incident to rules, is this what you base this practice on - an internal policy?

FYI Incident -to rules are not just recognized by Medicare , many of the commercial carriers have adopted Mcares incident rules as their own. There have been many things written regarding incident to billing, and basically if you have a carrier that expresses that they do not follow incident to then you must get this policy in writing and the policy must be clear that the payer recognises that the physician may not be in the office at the time of service and may have never evaluated this patient for this diagnosis previously.
Did know that...

incident-to may be recognized by other payers. For the upcoming audit on our clinics, we simply decided to use Medicare as a baseline to determine if there is a problem. Which started with the physicians signing every note...which I am still trying to see if this is allowed or not.

Thanks, Debra.
be sure to check the state laws regarding signatures as well. Often they require that the supervising physician sign all or a percentage of NPPs documentation.
State regulations / hospital policy

Our state requires physician counter signature on all services by an allied health professional.

To ensure that we (coders) know whether a service was performed independently or under direct guidance of the physician, we have specific wording that our NPs / PAs use when dictating notes.

"I performed this procedure/service on behalf of Dr Supervisor." means that the NP/PA was the sole provider.

(It might still be "incident to" but we know it's not a shared service or an assist at surgery.)

Hope that helps.

F Tessa Bartels, CPC, CEMC
Your reply is helpful to me on the "gray area" I am dealing with internally in a practice. If the P.A. sees a Medicare NEW pt - doesn't this HAVE to be billed under the P.A.'s NPI # at the 85% reimbursement? As for the commercial carriers - some say yes they credential P.A.'s and some say they do not. I will go the extra step to ask the commericals if they recognize the "incident to" rule and if they do then that will be more clear on how to bill the P.A services. If the carrier says they do not recognize incident to, but then they say it is not necessary to credential the P.A. (just bill under the group), will we get in trouble in the long run if all of the P.A's claims get billed just as if the physician saw the pt?