# Incident-to and med changes



## abranch13 (Mar 31, 2015)

Is it correct if a NP is seeing a pt for a follow up visit and end up changing the pts med doses, this cannot be billed as incident-to? My office sees mostly diabetic pts, they see the physician who establishes the plan of care, and often times come in for follow up with an NP.....if the NP has to change the pts insulin dosage at the follow up, does this make the visit no longer incident-to?  They are often times consulting with the physician when making the dosage change, but the NP is the one seeing the patient.

Any thoughts are appreciated!

Thanks


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## mitchellde (Mar 31, 2015)

This cannot be incident to even if the NP consults with the provider.  The provider would need to see the payient face to face and write the encounter note to charge a med chane using the provider NPI.


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## teresabug (Mar 31, 2015)

Hello Amy, here is a MLN Matters article re: this scenario. Check out page 3. Scenario presenting as the Pt is being seen for anticoag therapy that the MD initially saw the pt for... per this article, yes it can be billed incident to. 

https://www.cms.gov/Outreach-and-Education/.../se0441.pdf

Teresa


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## mitchellde (Mar 31, 2015)

The SE0441 you have referenced does not say it can be incident to if the treatment plan needs to be adjusted.  The NP must be following the plan of care already established. If the meds need to be adjusted then this is a new treatment plan and cannot be incident to.


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## teresabug (Mar 31, 2015)

I disagree. If that were the case, then there would be no point in an office ever scheduling a patient with a NPP once a POC has been established. Chances are pretty high that a pt on anticoag therapy is going to have continual meds dosage changes. 

Any one Else have an opinion?


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## mhstrauss (Mar 31, 2015)

My opinion is that CMS needs to clarify this issue in writing 

I agree with Debra that in order to meet Incident-to requirements, the NPP must follow the MD's POC.  However, I've asked for clarification during a Novitas provider call for this specific issue, and was told by the rep that the NPP can make medication changes, and as long as the MD remains active in the care of the patient (changes discussed with MD, MD signs off on the note, etc), then the visit can still be considered Incident-to. I believe this call was about a year ago.

Just my $0.02...


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## mitchellde (Mar 31, 2015)

Might be that the rep verbally stated that but the medicare policy on incident to states the one of the integral components of incident to is an established plan of care that is being adhered to.  If the NP changes the existing plan then this is no longer incident to as a new treatment plan is being initiated.  Unless medicare puts a new policy in place that it what is stated.


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## cheermom68 (Apr 1, 2015)

*Incident to*

Per WPS, this scenario does not meet incident to.  The only way to meet the requirements under this scenario is if the physician previously ordered the med change, i.e. "if HgbA1C gets above 10 increase insulin by ......"  This information was presented at their incident to seminar and can be found on their website  www.wpsmedicare.com (in writing) if you search incident to.

LeeAnn


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