Otolaryngology Coding Alert

Question: When administering shots to a patient whose physician is on vacation, should I bill for the service under that doctor or the physician who is in the office?

California Subscriber

Answer: You should bill the shots under the physician who is present in the office that day. To bill services or procedures incident-to a physician, the Medicare Carriers Manual section 2050 requires direct supervision. So the physician must be present in the office suite when the nonphysician practitioner administers the shots. The otolaryngologist does not have to be in the same room, but he or she must be immediately accessible throughout the procedure in case the patient has an anaphylactic reaction to the immunotherapy. Only the physician who is now in the office can provide direct supervision.

Billing the services to the patient's doctor who is on vacation is fraudulent. Some coders note that billing this way can prove problematic because they cannot accurately track each physician's services. In addition, some carriers deny claims that are billed under a different doctor than the prescribing physician. To meet Medicare's incident-to guidelines, however, you must bill these services under the supervising doctor. He or she is responsible and liable for any adverse reactions that occur that day.