ED Coding and Reimbursement Alert

READER QUESTION ~ State, Facility Will Have Final Say on NPP's Role

Question: Our coding company recently started processing claims for an ED that employs non-physician practitioners (NPPs). What types of services can NPPs provide, and what are the supervision requirements for these medical professionals?

New Mexico Subscriber

Answer: It depends on your state and particular hospital. While Medicare and third-party payers may allow you to code for certain services the NPP provides, state lawmakers and individual facilities are the ones that decide what procedures and services NPPs can perform.

Best bet: Check with the hospital and look at your state statutes to decide what NPPs can do in the ED. While it varies depending on the person, most NPPs are qualified to perform physical exams, start life support and reduce fractures.

Usually, NPPs perform evaluation and management (E/M) services, initial observation care service and observation discharge services. By CPT and Medicare rules, there is no limit to the service level an NPP can provide -- she can even perform a 99285 (Emergency department visit for the evaluation and management of a patient, which requires these three key components within the constraints imposed by the urgency of the patient's clinical condition and/or mental status: a comprehensive history; a comprehensive examination; and medical decision making of high complexity) service -- provided you meet the insurer's supervision requirements.

Supervision requirements: There are two types of NPPs generally used in the ED -- nurse practitioners (NPs) and physician assistants (PAs). And there are also different supervision rules depending on the type of NPP:

NPP rule: Medicare says that NPs need physician collaboration.

PA rule: Medicare requires PAs to be supervised by a physician.

Private payers may have more restrictive NPP supervision rules than Medicare, so make sure to call the insurer if you are the least bit unsure about its NPP reporting rules. Reader Questions and You Be the Coder reviewed by Michael A. Granovsky, MD, CPC, FACEP, vice president of Medical Reimbursement Systems Inc., an ED coding and billing company in Woburn, Mass.  
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