Oncology & Hematology Coding Alert

CMS may think so --  find out what the correct services are

If you-re reporting every NPP service incident-to a physician, you could be in big trouble come audit time. Protect yourself by learning which services CMS considers appropriate for incident-to billing.

Look for Individual Benefit Categories

You should report only services that don't have their own benefit category as incident-to a physician service, according to the Dec. 31, 2002, Federal Register.

What this means for you: Injections, EKGs, laboratory tests, and x-rays have their own statutory benefit categories and are subject to the rules applicable to their specific category. They are not considered incident-to services; incident-to rules do not apply.

Don't Use Physician's ID When NPP Supervises

Certain NPPs, such as physician assistants, nurse practitioners, clinical nurse specialists, nurse midwives, or clinical psychologists, may also supervise services. These services are subject to the same requirements as physician-supervised services.

The catch: When an NPP supervises a service performed by auxiliary personnel, you must report the service under the NPP's number, and you may only receive 85 percent reimbursement
. 
Watch for: Drugs and labs aren't subject to this reimbursement reduction.

Follow State Laws

State license laws determine the scope of practice under which NPPs can operate, says Barbara J. Cobuzzi, CPC, CPC-H, CHBME, president of CRN Healthcare Solutions.

So be sure that NPPs check their state licensure policy on incident-to as well as other services (such as their ability to prescribe) because the scope of practice may not align with Medicare.

The stricter set of laws takes precedence.

You should also have a collaboration agreement between the physician and the NPP.

Additional resources: Check the Medicare Carriers Manual (MCM) online for specific guidelines on different NPPs- scopes of practice.

Refer to section 2154 for a CNM, 2156 for a PA, 2158 for an NP, and 2160 for a CNS. For general incident-to guidelines see the -Services and Supplies- section of the online MCM (2050).