I personally spoke with an NGS clinical consultant just recently for guidance on this and was told that if anything happens during a visit that "violates" the guidelines it must be bill under the NP's NPI. The physician cannot come in and see the patient in order to bill under his/her number, you also cannot bill the visit based upon the original complaint only. I guess that you could tell the patient "You will have to come back for that problem" but that wouldn't be good PR and the patient would probably blow a gasket. I know I would.
She stated that only strictly follow up visits with no change in treatment plan can be considered "incident to"
How often does that happen??? Maybe a follow up of a simple ear infection or follow up of a simple injury. To me personally, billing incident to is not worth the hassle and risk and does not utilize the time and talents of the NP.
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