# Rules for PA billing?? Need answer ASAP!!!



## 1073358 (Nov 5, 2010)

Two questions:
1) Can a PA work in a building by themselves if billing under a supervising MD or does the supervising NEED to be on site?
2) Can a PA dx and treat a NEW problem?


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## mitchellde (Nov 5, 2010)

If the PA is billing under their own number they can see and treat new or established patients with or without a physician on site.  If you are billing with the physicians number that physician must be within the office suite area while the patient is being seen.  Since most payers follow CMS policies, then you should follow the CMS incident to policy which says this can only be a follow up encounter while the physician is on site.  If the payer states they do not follow CMS policy, it is heavily advised that you get it in writing from that payer.


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## nbluvette (Nov 5, 2010)

*Supervision Requirements for Physician Assistants*

There are two types of supervision required under Medicare regulations. One applies to "incident to" services and the other to "physician services."

"Incident to" services are those which are integral, although incidental, to a physician's professional service that is commonly furnished in a physician's office.  It requires that the physician "be present in the office suite and immediately available to provide assistance and direction throughout the time the physician assistant is performing services." However, this does not require the physician to be physically present in the same room as the physician assistant only in the office suite.

Physician services can also be performed by physician assistants. These are broadly defined under Medicare as "the type that are considered physician's services if furnished by a doctor of medicine or osteopathy." Again, the scope of these services would be limited by state law. The physician must be immediately available for consultation purposes by telephone or "other effective, reliable means of communication."

If a patient presents with a new problem that is within the Physician Assistant's scope of practice per state or organization he/she may evaluate the new problem and billing must be under the PA as a direct bill.  In other words...not under the physician's name and number. If the physician enters the scene shared billing may be appropriate if allowed by the payer.  Remember incident - to is only for Medicare.

Hope this is helpful.


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## mitchellde (Nov 5, 2010)

nbluvette said:


> There are two types of supervision required under Medicare regulations. One applies to "incident to" services and the other to "physician services."
> 
> "Incident to" services are those which are integral, although incidental, to a physician's professional service that is commonly furnished in a physician's office.  It requires that the physician "be present in the office suite and immediately available to provide assistance and direction throughout the time the physician assistant is performing services." However, this does not require the physician to be physically present in the same room as the physician assistant only in the office suite.
> 
> ...



While I agree with your definitions, even if you meet the definition of physician services you cannot bill these under the physician number if that physician is not on site.  Also while incident to is a CMS policy its use is not restricted to Medicare.  We must remember that CMS is considered the gold standard in this industry and while a payer may decided to have different policies they must provide their policy in writing.  So unless we see it in writing we must assume the carrier follows the CMS policy.  
A shared visit may be possible but the physician must write their own note and you may not have a shared visit for a new patient or a consult.


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## cindy holland (Nov 17, 2010)

*I have an additional question*

I have two insurance companies (United and Cigna) that will not credential a PA and tell me to bill under the MD's ID and NPI numbers.  If my PA sees the patient, how do I indicate on the claim form that she saw the patient and not the MD?  Is there a modifier that is similar to a Locums Q6?  Our doctor is always on the premisis.


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