Wiki PA performing E&M, Phyisian performing injection

[CJoy0724]

Can anyone verify, if a PA sees a Medicare patient, determines they need an injection, but then the physician performs the actual injection - that the injection is billed out under the physicians name, not the PA? If anyone has or knows of any documentation from Medicare on this it would be greatly appreciated!

 

[teresabug]

the injection would be billed out under the Physicians NPI. I would review the incident-to guidelines on cms website. Is the patient new to the practice? Does the patient have Medicare?
PA's cannot see Medicare pt's for their first visit; they have to establish care with an MD or DO. Hope this was helpful for you.

 

[CJoy0724]

Thanks, this is what I thought but have a provider disagreeing. I have reviewed the incident to guidelines and everything I can find is for the opposite situation, if the physician sees the patient and then the PA does an injection based on the treatment plan. For some reason, our provider is having the PA see the patient, and then if an injection is recommended he is doing it himself. Do you happen to know of any articles or anything in the manual that discuss this topic, so I can have concrete evidence for him?

 

[mitchellde]

There is a new OIG part of the work plan for this next year. It has to do with incident to and initial encounters. They have discovered that numerous new patient levels are being billed under the physician NPI when the service has been provided by the PA or NP. They stress that is never to be done and have included this issue specifically in the new work plan, which means they will be targeting new patient encounters for review.
If this visit does not meet the definition of incident to and it will not if it is determined that the patient needs a treatment such as an injection, then the visit level needs the PA NPI in field 24J and the injection will have the physician NPI in 24 J. If however the provider documents that he/she intervened during the encounter and determined that an injection was necessary then for an established patient this is a shared encounter and both services are billed with the providers NPI, but the provider must document a portion of the the visit not just the injection.