General Surgery Coding Alert

Question: We have some Registered Nurse First Assistants (RNFAs) in our group, and we've been informed that when they assist in surgery for hospital inpatients, we can bill incident to services using the surgeon's National Provider Identifier (NPI) number. Is this correct?

Michigan Subscriber

Answer: You are right to be wary of this advice. Incident-to does not apply in the inpatient setting because nurse services are built into the facilities' fees. Any nonhospital paid staff must bill independently.

Blue Cross Blue Shield (BCBS) of Mich. States that RNFAs should file under their own NPI using the CPT® code with modifier AS (Physician assistant, nurse practitioner, or clinical nurse specialist services for assistant at surgery).

Medicare does not currently reimburse RNFAs. Some state Medicaid payers and private payers do, however.

Do this: Contact your major payers for their requirements, because Physician Assistant (PA), Nurse Practitioner (NP), and RFNA billing is state specific subject to state scope of practice laws. Although many insurers would probably follow the same directions of direct RNFA reporting, you should make sure to comply with specific payer rules.