# Incident to for AWV



## pkoens (Nov 24, 2014)

My question pertains to AWV and incident-to services.  Our coding staff listened to the webinar presented by Michael Miscoe, Esq. on November 5, 2014 and what we think we heard was that AWV services did not qualify for Incident-to, however, one of our NPP's states that information is incorrect and we are trying to clarify this issue and find something stating that in writing.  I know a link was given , but we can't find anything that specifically states this and it was not addressed in the Q & A.

Thanks,


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## missy874 (Nov 24, 2014)

Perhaps this is because in order to be "incident to" the service has to be part of a treatment plan in which the physician personally performed an initial service and remains actively involved in the course of treatment.  Per MRN Matters SE0441

There wouldnt be an intial service that an AWV would be considered incident to.


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## pkoens (Nov 25, 2014)

That is exactly what we tried to explain to her, however, she was using a subsequent AWV as an example as to her reasoning for incident-to.


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## pkoens (Dec 1, 2014)

If AWV is not subject to incident-to rules, does the NP bill under her own Medicare # and is it reimbursed at 100% or 85%?   Again, I see a lot of information out there with many different answers.


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## mitchellde (Dec 1, 2014)

The NP must bill under his/her own NPI, the reimbursement will be 85% unless you are in a designated under served area.  The subsequent AWV applies to the patient and cannot be billed incident to, the word subsequent does not mean this visit is subsequent to the physician encounter it means this is the patient's subsequent annual wellness encounter.


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## pkoens (Dec 18, 2014)

Sorry to keep re-hashing this, but I was given information that stated the criteria for  NPP billing under supervising docs name was just that he/she needed to be onsite during AWV.  Is there anything in black and white that you have seen that states NPP must bill under his/her own #...or..that he/she can bill under  supervising doc?  I know that in order to resolve this issue with NPP I need something in writing to clarify policy.


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## mitchellde (Dec 18, 2014)

To bill under the supervising MD/DO number you must meet all of the incident to rules, the provider being within the office suite is only one of the provisions.  To read this go to the Medicare manual and look up incident to.  An AWV cannot be incident to as it will not meet all of the criteria.  Also look under share service, an AWV also is excluded from the shared service provision.


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## SharonSP (Dec 31, 2014)

*link for AWV*

http://www.cms.gov/Outreach-and-Edu...N/MLNProducts/downloads/IPPE_AWVQuestions.pdf

4) Are Physician Assistants and Nurse Practitioners subject to the incident-to rules for the Initial Preventive Physical Examination (IPPE) or Annual Wellness Visit (AWV) or will they be reimbursed at the full payment rate?
No. The Initial Preventive Physical Examination (IPPE) and Annual Wellness Visit (AWV) have their own respective benefit categories. Therefore, they do not fall under the incident to benefit category under section 1861(s)(2)(A) of the Act.
5)


http://www.cms.gov/Outreach-and-Education/Outreach/NPC/Downloads/2012-03-28-IPPEAWV-Transcript.pdf

I’d like to confirm that like the IPPE, the AWV is not subject to incident to rules. And where the wellness visit is performed by a team of medical professionals working under the supervision of the physician, it is the supervising physician who will bill Medicare for the visit. Also, in response to questions collected up from the registration page, I would like to take this moment to clarify that direct supervision in the office setting means that a physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure or service.

5) What is the definition for ?direct supervision??
?Direct Supervision" means that a physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. However, the AWV is not subject to "incident to" rules. Therefore, where a wellness visit is performed by a "team of medical professionals working under the supervision of a physician" it is the supervising physician who will bill Medicare Part B for the visit.


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## jlewis142 (Dec 31, 2014)

Our doctor is wanting to know if we can bill all of our codes "incident to" for our PA's to Medicare if the PA's are credentialed with Medicare? Thanks in advance


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