Gastroenterology Coding Alert

Question: We operate a large facility with several separate entities that include a gastroenterology physician group in an office setting plus a Medicare-approved surgery facility in separate suites.

If a nurse practitioner is seeing patients in the GI office suite, can the supervising physician be performing procedures in the surgery center suite for purposes of billing "incident-to?"

Missouri Subscriber

Answer: No, your physician must actually be in the office suite to directly supervise the nonphysician practitioner (NPP). Your first step in collecting for your incident-to claims is determining whether the services involved direct supervision. This means that the physician must be in the immediate office suite while the NPP is performing the incident-to services. You don't want to get caught using the term "direct" too loosely. Having the physician available by phone or having the physician somewhere on the grounds in a large facility is not acceptable. And you may want to check your state's practice requirements to see if your state mandates stricter supervision requirements than Medicare.

Be careful out there: Correctly billing your NPP's incident-to services means the difference between 85 and 100 percent reimbursement. But if you bill incident-to haphazardly, you could be inviting auditors' scrutiny.