Wiki NP Billing

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OmegaPM

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Our office is using "incident-to" billing for MD + 2 old NPs. We hired a new NP and her provider numbers are pending. Can she see patients on her own and have him sign her charts without him going into the rooms and seeing patients after her? Can we bill her visits under his Provider NPI number like we do with our other 2 old NPs? To clarify: she is not seeing any new pts or any established pts with new problems. She is only seeing well established patients while the physician is readily available should she have any questions. We want to make sure we are being 100% compliant in this process.
 
New np

Unfortunately, that form does not answer my question at all. Can someone help me figure out if a new NP with provider numbers pending see patients on her own and MD do the incident-to billing like he does with 2 other old NPs?
 
In general, billing for services performed under a different provider's number is fraud.

Trying to "get around" the fact that the NP does not have an NPI number by billing incident-to raises red flags to me. Especially since the provider you want to bill under did not have a face-to-face encounter with the patient.
 
It's pretty simple, no NPI, no billings. As Carol is stating, if the provider is trying to bill without an NPI number, but under a different provider, you are now qualifying the provider for a False Claim. Don't do this to your new provider, as everyone involved will get slammed by OIG, CMS and other entities.

Depending on your state, the link Chelle-Lynn provided could be helpful in determining other rules and rights for your NPs. However, apparently not based on your response.

In summary, I would be extremely cautious in moving forward with any "Incident-to" billing for a provider without any NPI number. I understand "Incident-to" might be an option if the provider has not yet been credentialed with certain insurances, but a provider without a NPI should not participate in any billings. All the guidelines/references I have looked up on this regarding "Incident-to", does not spell out the need for the NP to have her/his own NPI, however this is assumed as a general billing requirement.

Hope this is helpful, if not ask again!
 
Although I agree that caution in this situation is certainly warranted, I'm not sure this is such a serious issue. I do not know of any requirement that physician employees who are performing 'incident to' work in an office are required to have an NPI or otherwise go through a credentialing process with payers, (consider that the nurses and medical assistants routinely perform billable work for their physicians without an NPI or being credentialed with payers) so I'm not sure that there would be a compliance issue with having the NP see patients without this, as long as he/she is licensed to practice and is performing only 'incident to' services. I would point out however that just seeing established patients and having the physician sign the charts is not sufficient to meet the definitions of 'incident to' - you would also need to make sure that the NP is only performing work for existing problems that is within the physician's original plan of care.

All that said though, as with all legal and compliance issues, and since regulations and payer rules vary widely from place to place, it would be best to run this by your practice attorney rather than rely on forum posts for a definitive answer.
 
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cgaston said:
In general, billing for services performed under a different provider's number is fraud.

Trying to "get around" the fact that the NP does not have an NPI number by billing incident-to raises red flags to me. Especially since the provider you want to bill under did not have a face-to-face encounter with the patient.
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To clarify, the new NP has a lot of experience in our field and used to have all the insurances provider numbers at her old place of employment and DOES HAVE her NPI number and active state license and malpractice insurance coverage provided by us. The only thing that we are still waiting on are the provider numbers for her to be activated for our practice.
 
OmegaPM said:
To clarify, the new NP has a lot of experience in our field and used to have all the insurances provider numbers at her old place of employment and DOES HAVE her NPI number and active state license and malpractice insurance coverage provided by us. The only thing that we are still waiting on are the provider numbers for her to be activated for our practice.
Click to expand...

Are you referring to her provider billing numbers with the insurance companies?
 
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