Otolaryngology Coding Alert

Reader Questions:

Is NP-Run AI Clinic a Supervision Stickler?

Question: Our ENT supervises treatment board mixing on Saturday mornings. When our surgeon is in the hospital on Wednesday afternoons, can our nurse practitioner still provide allergy shots?

Texas Subscriber

Answer: Although the otolaryngologist may be off-site, the nurse practitioner (NP) may still hold allergy shot clinics in accordance with your state scope-of-practice laws. Because allergy immunotherapy (AI) and provisioning codes are not diagnostic procedures, CMS supervision concepts do not apply.

These circumstances will not meet incident-to criteria, which require direct supervision (physician must be in the office suite). Therefore, you must report AI when the physicians are off-site using the NP's national provider identifier (NPI) in Box 24J of the CMS-1500 form.

Caution: The physician must be on-site when staff mix the treatment board doses. Therefore, during the clinics, make sure you code for only the administration with 95115 (Professional services for allergen immunotherapy not including provision of allergenic extracts; single injection) or 95117 (- two or more injections). The ENT would code for the supervision of the antigen mixing when staff make up the treatments. For instance, if this service occurs on Saturdays, you would report 95165 (Professional services for the supervision of preparation and provision of antigens for allergen immunotherapy; single or multiple antigens [specify number of doses]) under the ENT's NPI.

Beware: Having the NP use her own NPI will cost you a 15 percent reduction in allergen immunotherapy pay. For instance, this would result in Medicare paying 95115 (0.33 relative value units) nationally -- about $10.68 instead of $12.57 using the 2008 fee schedule.

-- Answers to You Be the Coder and Reader Questions provided/ reviewed by Barbara J. Cobuzzi, MBA, CPC-OTO, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions in Tinton Falls, N.J

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