1. If it's just a nurse, and not an FNP taking the notes, they can't be used for E/M. The provider (eg, physician or non-physician practitioner) must document the HPI, exam, and MDM personally (or by use of a scribe) - they can't just piggyback off of someone else's work. The services must be within the nurse's scope of practice; if they're not licensed to provide E/M services, then they can't provide E/M services
2. If this does qualify for 'incident-to' billing, you'd only submit one claim for the doctor, not one for each of them.
See page 12: http://www.trailblazerhealth.com/Pub...ncident_to.pdf
"Requirements for â€śincident toâ€ť are:
The services are commonly furnished in a physicianâ€™s office.
The physician must have initially seen the patient.
There is direct personal supervision by the physician of auxiliary personnel, regardless of whether the individual is an employee, leased employee or independent contractor of the physician.
The physician has an active part in the ongoing care of the patient.
Direct supervision in the office setting does not mean that the physician/non-physician must be present in the same room with his aide. However, the physician must be present in the office suite and immediately available to provide assistance and direction while the aide is performing services....
The only NPPs who may bill E/M services (above the level of 99211) under the â€śincident toâ€ť criteria are NPs, CNSs, PAs and nurse midwives.
To ensure proper reimbursement according to the fee schedule, Medicare requires that documentation submitted to support billing â€śincident toâ€ť services must clearly link the services of the NPP to the services of the supervising physician."
3. A follow-up for chronic conditions/medication refills may not be billable as a level 4 E/M; you should check with your MAC over what they considered medically reasonable and necessary. Trailblazer, for example, requires that at least 3 distinct chronic conditions be evaluated (mentioned in the HPI), and treated (Mentioned in the MDM), in order to report a 99214 or 99215, and they have restrictions on the frequency of which follow-up visits are allowed. (Usually once every 3 months at most).
You may want to discuss changing the billing practice in your office, to one where you code off of the chart, as opposed to a superbill, to avoid these situations in the future. Something that's incorrectly marked on the superbill, or wasn't documented properly, could cause a sticky compliance issue, if the right hand doesn't know what the left hand's doing. You may find that it cuts down on claim denials, and that you catch charges that the physician might have forgotten to bill, so the benefits definitely outweigh the slight drawback of having to wait a little bit longer to enter the day's charges. Hope that helps!
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