Otolaryngology Coding Alert

Question: How do you handle allergy testing claims when performed by a non-physician practitioner (NPP) without a physician present?

New Jersey Subscriber

Answer: High-level NPPs — nurse practitioners (NPs), physician assistants (PAs), and clinical nurse specialists (CNS) — can provide some in-office services without the direct supervision of a physician or without the physician being present in the office unless state law rules otherwise. Some types of allergy injections can fall into this category.

What to do: Bill the allergy injection under the National Provider Identifier (NPI) of the NPP. Remember, however, that most allergy tests follow the supervision rules for diagnostic tests, which although they look like the rules for incident-to services, actually fall under separate rules within the Medicare Internet Only Manual: a physician must be present in the office (known as direct supervision) before the NPP can administer the allergy test and bill it under the physician’s NPI. Some tests require the physician to be in the exam room with the NPP (known as personal supervision), but these tests are uncommon for otolaryngologists.

Note: Administration of allergy immunotherapy shots is an incident-to service and follows all of the incident-to rules.

You should be allowed 100 percent of the fee schedule if auxiliary personnel (such as a nurse or medical assistant) perform the test and bill by the on-site supervising physician. If an NPP performs and bills the test, you’ll receive 85 percent of the allowable payment from Medicare.

Bottom line: Billing an allergy test under a physician’s NPI when that physician was not present in the office at the time is a serious compliance violation. If one of your NPPs administers an allergy injection and can bill it under a physician’s NPI, the NPP should include a note in the chart regarding which physician was present at the time. That will help you support the billing in case of an audit.