Wiki Pediatric Dietitian and Incident-to help please

morgan369

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Hello,
Our practice recently hired a pediatric dietitian and she is still going through the credentialing process with some payers, but most have come back and either credentialed or said not eligible (we are in WV if that matters or helps).
This is totally new to me, I have found the CPT codes 97802 and 97803 and talked with her that she needs to document time and so far I have been using Z71.3 as a primary diagnosis and then listing what else the patient has that she is covering, like obesity, diabetes, etc.
My question is really difficult to describe so I will try my best. The patient will be seeing another provider generally on the same day that they see the dietitian, typically like our endocrinologist. The dietitian wants to put her dietitian note in the middle of the other providers note, and the other provider bill a higher level of service... I have so far put a pause on this because I do not feel this is proper or correct....which means the other provider immediately is going to a level 5 office visit.
I know it does not fit Split/Share billing since the visits are taking place in the office setting, I am totally lost on Incident-to.
I am thinking the best practice is to each bill their service appropriately and the dietitian submit a separate note from that of the MD.
If someone is willing to help with this I would be greatly appreciative!
 
You have a few different issues going on here.
State scope, credentialing, incident-to questions, coding/billing, etc. You probably need guidance and input from your practice attorney, compliance team, C-level, rev cycle, and then coding and billing after that.
Trying to get around the fact that a health plan does not or will not credential an RD by burying the documentation inside an MD note is not the way to go. Unless the plan or specific contract tells your group to bill the RD that way.

Should a registered dietitian's services be billed “incident to” a physician's services?
It depends on the service rendered and the payer. Medicare allows a registered dietitian (RD) to provide most services in continuation of a physician's plan of care as incident to the physician's service as long as all other incident-to requirements are met. Examples include intensive behavior therapy for obesity when ordered by a primary care physician and provided within the physician's office by an RD who qualifies as auxiliary personnel to the physician. RDs may also provide an annual wellness visit (alone or as part of a team) when working under direct physician supervision and within the state-specific scope of practice rules. You should verify individual payers' policies. Incident-to billing rules do not apply to Medicare billing for diabetes self-management training or medical nutrition therapy services. However, in general, an RD may not be the sole provider of the diabetes self-management training service, and a physician who provides other Medicare services may bill for the entire self-management service as long as the program is accredited. Only an RD, nutritionist, or hospital that has received reassigned benefits from an RD or nutritionist can bill for medical nutrition therapy.


I would like to add a nutritionist to my staff. What is the best way to bill for his or her services?
Use the appropriate code from 97802–97804. These codes should be reported only for services provided by nutritionists. If a physician provides medical nutrition therapy, the E/M or preventive services codes should be used. Private payers may also accept HCPCS codes S9452, S9465 or S9470 for a session of nutrition therapy provided by a nutritionist. You might also consider offering medical nutrition therapy or diabetes self-management training services for Medicare patients. Medical nutrition therapy may be billed separately as a stand-alone benefit, and dieticians and nutritionists who apply for Medicare provider status can bill for services under both medical nutrition therapy and diabetes self-management training. For these services, you can use a CPT code from the 97802–97804 series, and when additional medical nutrition therapy is ordered in the same year, you can use G0270 and G0271. See Chapter 15, Section 300 of the Medicare Benefit Policy Manual at http://www.cms.hhs.gov/manuals/downloads/bp102c15.pdf for specifics on diabetes self-management training.

This is a few years old but has good info.

If the RD is a member of this organization, they have resources: https://www.eatrightpro.org/career/payment/coding-and-billing/coding-billing-handbook


You would have to check each health plan's policies and guidelines to see how/what/when/if it is covered and how to bill.
Example: https://www.aetna.com/cpb/medical/data/1_99/0049.html

Incident-to does not apply to medical nutrition therapy and diabetes self-management training services.
 
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