Ob-Gyn Coding Alert

A recent CMS memorandum means that you may be able to report nonphysician practitioner (NPP) services provided in the hospital as "incident-to" those performed by the ob-gyn. CMS transmittal 1776, released in October 2002, states that "when a hospital inpatient/hospital outpatient or emergency department E/M is shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient, the service may be billed under either the physician's or the NPP's unique personal identification number (UPIN)/personal identification number (PIN)." If no face-to-face contact occurs between the ob-gyn and the patient, even if the physician reviews the NPP's records, you should bill the service under the NPP's UPIN/PIN. The transmittal mainly affects billing for hospital visits, such as 99231-99233 (Subsequent hospital care), rather than office visits (for example, 99211-99215, Established patient office visit). For example, your NPPs can now bill for the morning rounds at the hospital as incident-to, as long as the ob-gyn visits the patients later that day. Incident-to rules, however, require the physician to initiate the plan of care. Therefore, you cannot report hospital admissions or initial office workups incident-to because this requires that the physician initiate the treatment. CMS used the memorandum to reinforce incident-to guidelines. The transmittal outlines three in-office billing methods:
1. If the physician performs the service, bill the E/M under the doctor's UPIN/PIN.
2. If the physician and an NPPshare or split an E/M, report the service incident-to, as long as it meets incident-to guidelines and the patient is an established patient. If the service does not meet incident-to guidelines, bill it under the NPP's UPIN/PIN. For instance, an NPP visits a hospital inpatient in the morning and the physician follows with a face-to-face examination that afternoon. Either the NPP or the doctor can report the E/M service (99231-99233). 3. If an NPP provides a portion of an E/M service and the physician completes the examination in an office setting, the physician reports the service (99211-99215) if it meets incident-to guidelines. Otherwise, the NPP bills the service under his or her UPIN/PIN. Section 2050 of the Medicare Carriers Manual outlines incident-to requirements. For you to report services incident-to a physician, the service must be:
an integral, although incidental, part of the physician's professional service
commonly rendered without charge or included in the physician's bill
of a type that is commonly furnished in physicians' offices or clinics
furnished by the physician or by auxiliary personnel under the physician's direct supervision. Direct supervision encompasses several issues. First, the physician must provide a direct, personal, professional service to initiate the course of treatment. Second, he or she must perform subsequent care [...]