Reader Questions:
Don't Overlook NPPs for Incident-To Services
Published on Sat Mar 12, 2005
Question: Should we consider time as a factor when coding for educational or counseling services that are provided by someone other than our ophthalmologist?
California Subscriber
Answer: In the office setting, only your ophthalmologist can consider time as a factor in selecting an E/M code (such as 99211-99215). You should not consider a nurse or medical technician's time in choosing the appropriate code to report for counseling in the office.
However, the rules are not as clear for nonphysician practitioners, such as physician assistants, nurse practitioners, or clinical nurse specialists. CMS' "shared visits" rule (CMS transmittal 1776, Oct. 25, 2002) implies that the services of both the ophthalmologist and the NPP are a cumulative effort. If more than 50 percent of the total service involves counseling/coordination of care, you can use the time spent by both to determine the level of visit code. Bill in the name and numbers of the physician for the total time spent.
Remember that shared visits are not applicable for consultations, critical care or new patients. If the NPP alone spends time counseling and coordinating patient care, report the level of service only under the name and numbers of the NPP. Advice for You Be the Coder and Reader Questions provided by Maggie M. Mac, CMM, CPC, CMSCS, consulting manager for Pershing, Yoakley & Associates, Clearwater, Fla; and Raequell Duran, president of Practice Solutions, Santa Barbara, Calif.