EM Coding Alert

Question: My physician has a patient that requires anti-coagulation monitoring in the office. Can we provide this as “incident to” services with a nurse practitioner performing the monitoring?

Wisconsin Subscriber

Answer: Yes, as long as you make sure the requirements for billing the service incident-to are met. CMS states the requirements in MLN Matters article SE0441 as the following:

1) The “incident to” services performed in the office are part of a course of treatment that the patient’s physician planned when she personally performed the initial service.
2) The physician is actively involved in the course of treatment.
3) The physician is physically present in suite when services are rendered by the employee.
4) The “incident to” service is billed under the physician’s ID or to whatever other legal entity that bills for the service.

Keep in mind, that if the physician recommends that the patient go to an anti-coagulation monitoring clinic, you can no longer bill the monitoring services as “incident-to.” The services have to be provided by an employee of the physician in her office, when she is on suite.