Wiki Standing Orders


Northeast Kansas Chapter
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I have a situation where a practice has nurses see patients under standing orders for immunizations, TB tests, and some labs. They want to bill these services under the chief of staff NPI number (due to the standing orders). The situation, I feel has gotten out of hand. Nurses may triage a patient for example who came in with urinary complaints and the nurse will do a UA and bill under the chief of staff. In the meantime another physician picks up the patient and orders the UA (as documented in the medical record). This other physician may go ahead and see the patient and order more tests, yet this practice wants to bill this under the chief of staff as the providing physician.

I feel this is wrong, that whomever sees the patient and/or write orders should be the billing physician. I have an administrator who disagrees. Where can I find it documented as to the appropriate way to bill this?
Are you billing as a facility or an office practice? If this is a facility, any services not personally performed by the provider (e.g. labs, immunizations) will go on the facility claim - you can't bill these 'under' a physician NPI because they will go on the hospital's UB claim. In an office, you would want to follow the 'incident to' rules and in those cases would bill under the physician who is supervising the services at the time. But I'm not sure I completely understand your question, so perhaps you could clarify a little what type of provider you're working with.
Standing orders

This is a clinic that has ~15 providers. Physicians see patients just like any other physician practice. The difference is there is a "walk-in" treatment clinic as a part of this practice. Practice physicians rotate in this walk-in clinic. Nurses provide triage services as well. The nurses in triage are able to use "standing orders" to order a UA for example if the patient complaint warrants it. When that happens, often the provider in the treatment clinic will then write an order for the UA and will supervise the encounter and sign the medical record. The supervising physician in the treatment clinic is not the chief of staff. I have a problem billing this using the chief of staff's NPI number. I believe the physician who wrote the order and signed the record should be the one the billing physician.
Nurses can triage patients for severity. They cannot diagnosis and they cannot order tests. So a provider must examine each of the patients and must write a note the service is billed under that physician.