Report Incident-to Services While the Plan Author Is Away
Published on Wed Feb 02, 2005
... if a qualified supervising physician is on-site
Many oncology offices employ at least one, and sometimes several, nonphysician practitioners (NPPs). But even offices with a whole staff of NPPs may have missed out on a rule that can allow your office to report NPP services more frequently.
Did you know? When an NPP provides services incident-to the physician, you can list two different doctors as the ordering and supervising physicians, says Jean Acevedo with Acevedo Consulting in Delray Beach, Fla.
Many oncology coders were unaware of this rule and decided to absorb the charges when the NPP performed a service for a patient whose plan-of-care author wasn't on-site. This course of action can cost offices reimbursement they are rightfully entitled to.
CMS has always allowed you to report NPP services when the plan author isn't available to supervise. But so many coders were misinterpreting this NPP rule that CMS released a clarification on incident-to billing when an NPP follows a plan of care for a physician who isn't present in the office.
Read on for an explanation of the CMS clarification, as well as some expert input on how your oncology practice can put this information to good (and profitable) use. NPP Role Depends on Setting The role of NPPs in an oncology practice varies by office, but they can be a huge boost for offices that treat patients with chemotherapy. "In our practice, the NPPs are a very important and integral part of the oncology team. The 'team' for an individual [chemotherapy] patient will consist of the MD, an NPP, and the registered nurse," says a compliance specialist in a large Boston practice.
Other NPP roles: NPPs can also provide other services incident-to the physician, such as patient education, follow-up visits, and some hydration and injection therapies.
For example: A patient undergoing chemotherapy for colon cancer reports to the office for a scheduled follow-up visit after his first round of chemo. Following the treatment plan author's (the physician's) written instructions, the NPP counsels the patient briefly and takes a blood sample for analysis.
On your claim, you should report 99211 (Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem[s] are minimal. Typically, 5 minutes are spent performing or supervising these services) incident-to the supervising physician.
Exception: In order to report an E/M service for the above scenario, the physician must have scheduled the patient for a medical service that did not require physician attendance. If the patient reported specifically for a blood draw, leave 99211 off the claim and report 36415 (Collection of venous blood by venipuncture) instead. Transmittal Clarifies 'Supervising Physician' To report this [...]