Oncology & Hematology Coding Alert

Incident-To in the News:

CMS Loosens Physician Rules

Supervising physician can fill in for the plan author

Oncology offices now have more freedom when reporting incident-to services if the plan-of-care author isn't present - as long as there is a qualified supervising physician in the office suite.

CMS reported that another member of the same physician group can supervise a nonphysician practitioner (NPP) who is following the plan of care of a physician who isn't present.

You Must Bill Under Same Group PIN

Example: Physician 1 has outlined a plan of care to treat Patient X's leukemia. Two weeks after Patient X starts her treatments, Physician 1 goes on vacation for two weeks.

During Physician 1's vacation, Patient X has a checkup scheduled. An office physician assistant (PA) performs the checkup with Physician 2 available in the office suite.

Under CMS' revised policy, the office may still be able to report the checkup incident-to the physician even though the plan-of-care author (Physician 1) was not in the suite at the time of Patient X's checkup.

How? The supervising physician (Physician 2) must bill under the same group PIN as the other physician (Physician 1) and must have signed a form 855R reassigning his right to bill to the group. You should identify the supervising physician "in 2310B loop" and list his PIN in REF02 and the IC qualifier in REF01, CMS instructs.

CMS Also Clarifies 'Suite' Definition

The transmittal also reported that when there is no "suite of rooms" in the office, then the supervising physician must actually be in the same room as the supervised provider.

Note: This report was based on CMS Change Request 3460, from Sept. 17, 2004.