Gastroenterology Coding Alert

While Doctor's Away, Incident-to Reporting Still Possible

'Supervising physician' does not have to be the plan author Most gastroenterology coders may have missed out on a rule that makes it a little easier to report NPP services: Did you know that Medicare permits reporting incident-to services provided by an NPP under a supervising physician other than the physician who authored the    care plan?

In a gastroenterology office, coders have to apply the rules of incident-to billing for nonphysician practitioners (NPPs) all the time - especially if your gastroenterologist treats patients with conditions requiring extended plans of care. But many coders have questions about this.

To clear up confusion about the rule for billing incident-to, CMS was compelled to release a clarification on incident-to billing when an NPP follows a plan of care for a physician who isn't present in the office.

Change Will Affect Some Long-Term Gastro Coding While gastroenterologists can use NPPs in several capacities in a gastro office, they "are very important to the care of hepatitis patients. They can perform the follow-up visits, as well as the patient education," says Linda Parks, MA, CPC, CMC, CMSCS, an independent coding consultant in Lawrenceville, Ga.

In addition to hepatitis patients, gastro offices are likely to use NPPs to provide incident-to services for patients with Crohn's disease or ulcerative colitis, Parks says.

If you're not aware of the contents of a recent CMS statement explaining the rules on coding incident-to for a physician who isn't present in the office, your office's policy on incident-to reporting may be askew. Read on for an explanation of the CMS clarification, as well as some expert input on how your gastroenterology practices can put this information to good (and profitable) use. Supervising Physician Not Always Plan Author In September 2004, Medicare released a statement explaining its rule on supervising physicians and NPPs. The statement basically reported that another member of the same physician group can supervise an NPP who is following the plan of care of a physician who isn't present in the office.

Explanation: This clarification means that the supervising physician does not have to be the physician who originally authored the plan of care, says Shannon O. Smith, CRTT, CPC, consultant auditor with Doctors Management in Knoxville, Tenn.

Therefore, you can certainly bill for your NPPs' services when the plan-of-care author does not supervise - as long as there is another qualified supervising physician on hand.

Example: Gastro A is the plan-of-care author for Patient X, who has Crohn's disease. One Monday, Patient X reports for a follow-up visit. Gastro A is away at the hospital, but Gastro B is in the office suite and available should the need arise.

The NPP takes a blood sample from Patient X, answers several questions and performs [...]
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