# Future incident to when PA/NP does inital visit?



## alincoln (Mar 28, 2012)

Was wondering what everyone thought about this situation:
PA/NP sees patient for the first time (consult/new patient) and has Medicare. The plan of care is developed and documented by the PA/NP. The service is billed independently under the PA/NP NPI number.

Do all future visits with this patient, for the same problem, have to be billed independently?
What if a physician sees the patient at the second visit and then the third visit they see the PA/NP again? Can that third visit be billed under incident to/the physician's NPI number, assuming that the physician was in the office providing direct supervision?

Thanks for any opinions!


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## Herbie Lorona (Mar 29, 2012)

I was told they could once by a speaker at one of the conferences. I still have never found any documentation about it.


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## valleycoder (Mar 31, 2012)

I'd only bill the established visits as incident to if the MD initiated the treatment plan.  If the NP did the initial, don't bill the subs as incident to.  The best way to eliminate having to monitor who initiated the plan is to not allow mid levels to see new patients.  Just a suggestion...


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## alincoln (Apr 2, 2012)

valleycoder said:


> I'd only bill the established visits as incident to if the MD initiated the treatment plan.  If the NP did the initial, don't bill the subs as incident to.  The best way to eliminate having to monitor who initiated the plan is to not allow mid levels to see new patients.  Just a suggestion...



That's what I was feeling too and suggested, but doesn't appear the providers want to go with that plan... They want the NPPs to be able to do new/initial visits if needed.  It doesn't happen very often, but wanted to have some opinions before we finalized what they should be doing.

Thank you!


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## cordelia (Apr 6, 2012)

So if an established patient sees the MD for pain and they decide to hold off on surgery. When the patient returns and sees the PA, the patient decides he now wants surgery. Can the PA bill incident to? Or because the treatment plan of surgery wasn't decided by the MD the PA must bill under his own NPI?


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## alincoln (Apr 6, 2012)

cordelia said:


> So if an established patient sees the MD for pain and they decide to hold off on surgery. When the patient returns and sees the PA, the patient decides he now wants surgery. Can the PA bill incident to? Or because the treatment plan of surgery wasn't decided by the MD the PA must bill under his own NPI?



Assuming the MD (or a member of the same group) was in the office that day with the PA, I would say yes.  I'm assuming that on the initial visit with the MD they discussed surgery as an option and the patient decided to hold off.  I would say that would count as the MD coming up with the plan that included surgery as an option... 

What do you guys think?


Since I posed the originial question - I have asked around and someone else suggested that if the PA/NP initiated the plan, then the pt sees an MD and they document that they agree with the plan and/or make changes to the plan AND that the pt can follow up with either themselves or the PA/NP in the future, that this would allow the PA/NP to bill inicident to for future visits... opinions?


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