Wiki Participation

[Nancy Klein]

Can an NPP choose not to par with Medicare (they are eligible to) and still bill incident-to under the supervising physician (who is par)? I think Medicare would want the NPP to par in this instance but the office is questioning it.
Thank you!!

 

[jkyles]

Hi sorry, I'm a bit confused by this scenario. I know the NP has to accept assignment: are they employed your practice but non-par?

 

[thomas7331]

Can an NPP choose not to par with Medicare (they are eligible to) and still bill incident-to under the supervising physician (who is par)? I think Medicare would want the NPP to par in this instance but the office is questioning it.
Thank you!!

I'm not aware of any CMS rule that requires the NPP (or any other employee) who is performing 'incident to' services to themselves be enrolled or participating with Medicare. For 'incident to' services, they are simply acting as a staff member and carrying out the care plan of the physician and all claims are billed as if the physician performed the services and are paid based on the physician's relationship with Medicare, so there's no need for the NPP to separately enroll if that's all they are doing. Just keep in mind that this severely limits the NPP's role in that they can not treat any new patients, or new problems for existing patients, and cannot change the care plan unless their supervising physician re-evaluates the patient.

 

[Nancy Klein]

Hi sorry, I'm a bit confused by this scenario. I know the NP has to accept assignment: are they employed your practice but non-par?

That is correct. The PA is employed but does NOT par. I did get ahold of WPS enrollment department and was told if billing incident-to they could run into trouble IF all the rules weren't followed (established patient with a new problem OR a new patient). I was hoping for something in writing though.

 

[Nancy Klein]

I'm not aware of any CMS rule that requires the NPP (or any other employee) who is performing 'incident to' services to themselves be enrolled or participating with Medicare. For 'incident to' services, they are simply acting as a staff member and carrying out the care plan of the physician and all claims are billed as if the physician performed the services and are paid based on the physician's relationship with Medicare, so there's no need for the NPP to separately enroll if that's all they are doing. Just keep in mind that this severely limits the NPP's role in that they can not treat any new patients, or new problems for existing patients, and cannot change the care plan unless their supervising physician re-evaluates the patient.

Thank you!!! Another Question I hope you have the answer to: Regarding Incident-to: What does the rules stating: "Services and supplies having their own benefit category are not subject to incident to guidelines" mean? Specifically, if a patient is seen incident-to and in addition is receiving a vaccine can both the E&M and the vaccine be billed under the supervising provider?

 

[Nancy Klein]

Thank you!!! Another Question I hope you have the answer to: Regarding Incident-to: What does the rules stating: "Services and supplies having their own benefit category are not subject to incident to guidelines" mean? Specifically, if a patient is seen incident-to and in addition is receiving a vaccine can both the E&M and the vaccine be billed under the supervising provider?

Now that I'm thinking about it: If the patient only comes in for an immunization/vaccination and a non-par PA were to administer it, can it be billed under the participating doctor the PA works for?

 

[jkyles]

Now that I'm thinking about it: If the patient only comes in for an immunization/vaccination and a non-par PA were to administer it, can it be billed under the participating doctor the PA works for?

That sounds like a new problem so it would be billed by the PA.

 

[thomas7331]

Now that I'm thinking about it: If the patient only comes in for an immunization/vaccination and a non-par PA were to administer it, can it be billed under the participating doctor the PA works for?

I would not interpret this to mean it is OK to bill these under the physician.

The legal language here is confusing, but I understand this to mean that items that are in a different benefit category (e.g. preventive services) do not fall under the 'incident to' requirement because those items are normally not part of a physician's plan of care for the diagnosis and treatment of an illness or injury. In other words, preventive services such as immunizations are not something that a physician orders for a patient in order to treat an illness, yet they are still covered because they fall into a different category under the law. So I would be very hesitant to bill these under a physician's credentials unless you can get confirmation from a legal or compliance specialist that this is allowed.