ED Coding and Reimbursement Alert

Question: If nurse practitioners (NPs) are employed by the emergency physician group rather than the hospital, can the physician group bill for an NP's services as -incident-to,- or does the group have to bill under the provider number of the NP?


California Subscriber


Answer: In general, the incident-to provision is not allowed in the emergency department. Services provided by techs, nurses, or other hospital employees are reimbursed to the hospital through Medicare Part A, not through billing Medicare Part B on behalf of the physician.

However, in this case, the NP is employed by the physician group, so there is not an incident-to conflict. The rules governing shared visits by physicians and non- physician practitioners (NPs and physician assistants) are spelled out in Medicare CMS Transmittal 1776. You can view this transmittal online at http://www.acep.org/NR/rdonlyres/6ACEB786-9A34-467A-A4DFFA8CE08735B5/0/medCarriersTrans1776.pdf.

According to the transmittal, -The physician collaboration and general supervision rules as well, as all billing rules, apply to all the above practitioners.- The transmittal also reminds practices that -the service provided must be medically necessary and the service must be within the scope of practice for a nonphysician practitioner in the State in which he or she practices.-