Wiki NP cosign for non-credentialed NP

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I have taken over the billing for a small practice that employs 3 NP's of which only 1 of them is fully credentialed at the moment. The previous biller had been submitting claims under the credentialed NP's NPI as rendering (when the non-credentialed NP performed the care) and billing under a group NPI. I have been told this is how they have always done it. I'm not sure I agree with this process? Appreciate any feedback.

Thanks,
Robin Cruz, CPC,COC
 
I would not bill under a provider who did not render the service unless it falls under incident-to or locum tenens. Both of these do not apply to one NP submitting under another NP. I cannot tell you how many times I have heard in my career - "but we've always done it this way." Having done it incorrect in the past does not justify doing it incorrect in the future. This could be considered fraud as you are intentionally submitting dishonest information in order to receive payment.
Here is my personal recommendation when you have a new provider (whether NPP or physician) who is not yet credentialed.
1) Submit credentialing ASAP. I try to do this before provider has even started. I start the process the day the employment contract is signed.
2) Until that provider is credentialed, you need to make a business decision about what work they provide. I try to maximize the amount of work they provide that is either not paid or billable correctly. Examples of work not paid: postop visits, rx renewals, patient phone calls for triage or results, afternoon hospital rounds after another clinician rounded in the morning. Once they start becoming credentialed, keep an updated list of those insurances and funnel patients with those plans to the new provider. Schedule all self pay patients with this new clinician.
3) If the new provider is an NPP, schedule as much as possible that could be billed incident-to a physician. There are a few rules about this, so make sure you are following them. For example: physician must be onsite, treatment plan must already be determined by physician, etc.
4) If you have any commercial carriers that do not credential NPPs and want services billed under physician, that is another option. Side note: this used to be common, but none of my current carriers want this. Your contracts/carriers could vary.
5) You may decide it is in the best interest of patient care and the practice for this clinician to sometimes provide care that you know you will not be covered under insurance. You could decide to provide the services for free. Create a dummy code in your system that does not get billed to insurance to track the work for your own knowledge (provider metrics, etc.) You could inform patients that the provider is not credentialed and they would be billed for any insurance applied deductible/co-insurance. I would have them sign an acknowledgement of this. Some carriers could require a specific form for this.
Issues like this are sometimes best handled by a compliance department (if you have one). Often it's just simply a lack of knowledge about how incorrect this is. Educate the practice, and offer collaborative solutions that could include some of my suggestions.
 
I have taken over the billing for a small practice that employs 3 NP's of which only 1 of them is fully credentialed at the moment. The previous biller had been submitting claims under the credentialed NP's NPI as rendering (when the non-credentialed NP performed the care) and billing under a group NPI. I have been told this is how they have always done it. I'm not sure I agree with this process? Appreciate any feedback.

Thanks,
Robin Cruz, CPC,COC
Your instincts are correct. Unless the practice can demonstrate something in writing from the payers to which they've submitted these claims (e.g. a payer policy or contract clause) that shows that the payer allows or has agreed to having services billed under a different provider during the credentialing process, then those are quite simply false claims.
 
Your instincts are correct. Unless the practice can demonstrate something in writing from the payers to which they've submitted these claims (e.g. a payer policy or contract clause) that shows that the payer allows or has agreed to having services billed under a different provider during the credentialing process, then those are quite simply false claims.
Thomas,

Thank you for your response.

Thanks,
Robin Cruz, CPC, COC
 
I would not bill under a provider who did not render the service unless it falls under incident-to or locum tenens. Both of these do not apply to one NP submitting under another NP. I cannot tell you how many times I have heard in my career - "but we've always done it this way." Having done it incorrect in the past does not justify doing it incorrect in the future. This could be considered fraud as you are intentionally submitting dishonest information in order to receive payment.
Here is my personal recommendation when you have a new provider (whether NPP or physician) who is not yet credentialed.
1) Submit credentialing ASAP. I try to do this before provider has even started. I start the process the day the employment contract is signed.
2) Until that provider is credentialed, you need to make a business decision about what work they provide. I try to maximize the amount of work they provide that is either not paid or billable correctly. Examples of work not paid: postop visits, rx renewals, patient phone calls for triage or results, afternoon hospital rounds after another clinician rounded in the morning. Once they start becoming credentialed, keep an updated list of those insurances and funnel patients with those plans to the new provider. Schedule all self pay patients with this new clinician.
3) If the new provider is an NPP, schedule as much as possible that could be billed incident-to a physician. There are a few rules about this, so make sure you are following them. For example: physician must be onsite, treatment plan must already be determined by physician, etc.
4) If you have any commercial carriers that do not credential NPPs and want services billed under physician, that is another option. Side note: this used to be common, but none of my current carriers want this. Your contracts/carriers could vary.
5) You may decide it is in the best interest of patient care and the practice for this clinician to sometimes provide care that you know you will not be covered under insurance. You could decide to provide the services for free. Create a dummy code in your system that does not get billed to insurance to track the work for your own knowledge (provider metrics, etc.) You could inform patients that the provider is not credentialed and they would be billed for any insurance applied deductible/co-insurance. I would have them sign an acknowledgement of this. Some carriers could require a specific form for this.
Issues like this are sometimes best handled by a compliance department (if you have one). Often it's just simply a lack of knowledge about how incorrect this is. Educate the practice, and offer collaborative solutions that could include some of my suggestions.
Christine,

I truly appreciate the information you have provided. Thank you so much!

Thanks,
Robin Cruz, CPC, COC
 
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