Neurosurgery Coding Alert

Has the NPP Executed A Plan of Care? Find Out Before Reporting Incident-To

Medicare is the only payer that consistently recognizes these services If you don't know all of the situations in which you can report services provided incident-to the neurosurgeon's services, your practice is likely missing out on hard-earned reimbursement.

Why? If a nonphysician practitioner (NPP) performs a service that qualifies as incident-to a physician, the office can bill under the physician's Medicare number and secure 100 percent reimbursement. But if the NPP's services are not provided incident-to the physician, you must bill under the NPP's number, which will garner 85 percent reimbursement for the same service.

When deciding whether a service can be billed incident-to the neurosurgeon, you must ask yourself the following questions. If you can answer -yes- to all of them, you should be able to report the service incident-to rather than under the NPP's Medicare number, thus raking in 15 percent more revenue for the service:

- Is the neurosurgeon present and available? Medicare says the supervising neurosurgeon must be -present and available in the office- when the NPP sees the patient in order to bill incident-to.

-Present and available in the office means that there is direct [physician] supervision, which means that the physician is physically present and readily available in the office suite,- says Chris Felthauser, CPC, CPC-H, ACS-OH, ACS-OR, PMCC, medical coding instructor for Orion Medical Services in Eugene, Ore.

So if the supervising neurosurgeon is in the next examining room at the facility, you can still report incident-to services. But if she is off-site and only available by cell phone or e-mail, report the service under the NPP's number.

Example: An NPP conducts an E/M service to check on how well conservative therapy is working for an established symptomatic postlaminectomy patient. The NPP performs a level-two evaluation and management service on the patient. The physician is in the office supervising but does not see the patient. 

-Incident-to requirements were met; this is an established patient with an established problem and plan of care, and the physician is in the office. You may bill incident-to the physician using the physician's UPIN/PIN for the NPP's service,- says Jennifer Schmutz, CPC, health information coder with Neurosurgical Associates LLC in Salt Lake City.

On the claim, you should report 99212 (Office or other outpatient visit for the evaluation and management of an established patient, which requires at least two of these three key components: a problem-focused history, a problem-focused examination, straightforward medical decision-making) as incident-to the physician's services.

Remember: Any services the NPP provides incident-to the physician -must also fall under the scope of licensure for the NPP in whatever state he or she is practicing in,- Felthauser says.

- Is the patient following an estblished plan of care? If the physician has not established a plan of care [...]
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