The OIG is watching, so be sure to meet the incident-to standard. The Office of the Inspector General's (OIG's) recent discovery that unqualified nonphysician practitioners (NPPs) performed 21 percent of incident-to services is sure to have Medicare auditors focused on documentation for claims of commonly performed technician services/procedures. Many practices believe that as long as they meet the minimum requirements of incident to (the physician is onsiteand sees patients for any new problems), they can report all types of tech services incident to and collect their extra 15 percent of Medicare reimbursement. In many cases, "physicians feel as long as they can just simply peek in or sit somewhere nearby, they're covered by these rules," unaware that there is more to it for the different types of services these offices perform, suggests Leslie Johnson, CPC, coding supervisor for Duke University Health System and owner of the billing and coding Web site AskLeslie.net. Reality: Include Visual Acuity, IOP Tests in Exam Level Question: Answer: be involved in the service that day or have initiated care of the patient, made a plan of care, and remained involved in the patient's care. The tech must also meet the supervision requirements. The Medicare Benefit Policy Manual limits incident-to coverage to "situations in which there is direct personal physician supervision." Medicare takes the "direct supervision" rule quite literally, so make sure you meet the supervision requirement before considering incident to. In short,"direct supervision means the physician is on site and immediately available" during the tech's service, explains Susan Garrison, PCS, FCS, CCS-P, CHC, CPC, CPCH, CPAR, executive vice president of Magnus Confidential Inc. in Atlanta. Example: Since the ophthalmologist and the tech performed a total of seven tests, the exam portion of the E/M service qualifies as "expanded problem-focused." That and the low-complexity medical decision making (MDM) qualify the service for code 99213 (Office or other outpatient visit for the evaluation and management of an established patient ...). Watch out: Local coverage determinations may differ in the number of tests required to reach a certain E/M or eye code (92002-92014) level. Check your LCD for specific requirements. Hidden trap: Check Supervision Requirements Question: Answer: What to do: The number "1" in column AF indicates the test "can be performed under the general supervision of a physician," according to Medicare. The physician maintains overall direction and control of the procedure -- but his presence is not required. In other words, the physician must order the diagnostic test but does not need to be in the office when the technician performs the test. The following diagnostic tests have a general supervision requirement: • 92060 -- Sensorimotor examination with multiple measurements of ocular deviation (e.g., restrictive orparetic muscle with diplopia) with interpretation and report (separate procedure) • 92065 -- Orthoptic and/or pleoptic training, with continuing medical direction and evaluation • 92081 -- Visual field examination, unilateral or bilateral, with interpretation and report; limited examination ... • 92082 -- ... intermediate examination • 92083 -- ... extended examination • 92135 -- Scanning computerized ophthalmic diagnostic imaging with interpretation and report, unilateral • 92250 -- Fundus photography with interpretation and report. Look for: • 92235 -- Fluorescein angiography (includes multiframe imaging) with interpretation and report • 92240 -- Indocyanine-green angiography (includes multiframe imaging) with interpretation and report. Note: