# Billing for RN services with no supervising provider in the office



## maryek28@outlook.com (Apr 5, 2019)

I work in an outpatient medical and mental health clinic with 2 locations. My location is mainly admin staff and social workers. We do have an ANP and an RN at this location, but the ANP is moving his office to our other location. The problem is that the nurse wants to remain here and continue to perform med injections and lab draws. Is this allowed? I don't see how we can bill for these services with no supervising provider present. This is a totally new experience for me so I am totally confused about this. Most of our patients are Medicaid and Medicare, but we do see some other insurances as well.


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## thomas7331 (Apr 5, 2019)

Is your clinic part of a hospital or a freestanding clinic?  If part of a hospital, there is a limited list of outpatient therapeutic services published by CMS which have been approved for a 'general' level of supervision which does not require the presence on site of the provider (although the other requirements of supervision at this level must still be met), and you can bill these, on the hospital claim, if performed by the RN.  If you are a freestanding clinic that is not part of the hospital, then you will be much more limited in what can be billed.  I believe that CMS does allow an exception to the 'incident to' rules for coverage of immunizations, but beyond that, there will not be much that can be billed without a provider on site.


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## maryek28@outlook.com (Apr 10, 2019)

Thank you! We are a free standing clinic, not part of a hospital. So is this true for non medicare insurances as well? I know we probably can't bill under the provider's NPI when he is not here but are we allowed to bill under the RN's NPI? I'm very new to billing so this may be a dumb question.


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## mitchellde (Apr 10, 2019)

RNs do not have NPI numbers.  Also you should look at the state regulation for free standing physician offices.  Most will indicate that a provider must be present in the office when patient are being seen and treated.  an RN, MA are not providers, they are ancillary personnel.


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## TThivierge (Apr 10, 2019)

*Billing with RN or NP*



maryek28@outlook.com said:


> I work in an outpatient medical and mental health clinic with 2 locations. My location is mainly admin staff and social workers. We do have an ANP and an RN at this location, but the ANP is moving his office to our other location. The problem is that the nurse wants to remain here and continue to perform med injections and lab draws. Is this allowed? I don't see how we can bill for these services with no supervising provider present. This is a totally new experience for me so I am totally confused about this. Most of our patients are Medicaid and Medicare, but we do see some other insurances as well.



Hi
If the RN nurse is a certified nurse pracitioner you can bill for her. She will get her own NPI number  (no RN staff gets a NPI #) but the med director 's name and guidance  should be listed on each med record  and claim since he oversees NP works on. Also NP when using Medicaid as a payer have own  modifiers linked to CPT service when they  treat patients . Ensure your NP 's document properly the  HPI,  med history of patient,  and describe  current problem of the patient with details.  

I hope this info helps you

Lady T


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## pscanlan (Apr 10, 2019)

TThivierge said:


> Hi
> If the RN nurse is a certified nurse pracitioner you can bill for her. She will get her own NPI number  (no RN staff gets a NPI #) but the med director 's name and guidance  should be listed on each med record  and claim since he oversees NP works on. Also NP when using Medicaid as a payer have own  modifiers linked to CPT service when they  treat patients . Ensure your NP 's document properly the  HPI,  med history of patient,  and describe  current problem of the patient with details.
> 
> I hope this info helps you
> ...


To clarify the above, the situation described in the original post has the NP moving to a different location, with the RN wanting to bill on her own. There is no dispute about the NP being able to bill on his own, but the RN cannot. RNs must be supervised by an on site medical provider, except in certain on-campus outpatient facilities (as described by Thomas above) and other niche applications. In short, the RN formally needs a provider on site to supervise and delegate work, regardless of how independently the RNs work in actuality. The provider being at a different location almost certainly prevents him from supervising the RNs workload.


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## maryek28@outlook.com (Apr 12, 2019)

Our RN does have an NPI.... maybe my state allows it?


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## mitchellde (Apr 12, 2019)

I doubt your state allows RNs to work independent and bill for their services in a physician office setting... Is it perhaps she has another license such an OT or PT and has an NPI to provide those services... or does she also work home health and have a home health NPI?  you should really check and see if she does have an NPI what exactly does it pertain to.  Or is she ARPN or an NP and not an RN?


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## maryek28@outlook.com (Apr 15, 2019)

She is an RN. She does do medication pass at our residential campus for our mental health clients. I'm guessing that must be why she has an NPI


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## mitchellde (Apr 15, 2019)

Probably , but it would not cover her in an office setting.. You would need to credential her to work as a provider to be able to bill under that NPI number, I am willing to lay odds the payers will reject it.


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