Otolaryngology Coding Alert

Question:  What is the rule for administering an allergy shot without a provider present? I think the risk is too high to do without a physician or PA/NP present, but my allergy person disagrees. 

Georgia Subscriber 

Answer: A practice cannot bill for incident to services (the rule that allows you to administer a shot by a nurse or allergy technician and bill it under a doctor’s NPI unless there is direct supervision of the service. Direct supervision means that a physician must be present in the office. You cannot have incident to a PA or NP, but the NP or PA may administer the allergy injection themselves and you must bill the injection under his or her NPI. 

Remember: Medicare and all other payers consider billing incident to services under a doctor who was not present in the office suite as “billing for services that WERE NOT PROVIDED.”  This is because although your PA or nurse gave the shot, the provider whose NPI was used was not supervising the service, so he or she did not provide it and this is a huge area of non-compliance. It is actually recommended that the person who gives the allergy injection indicates which doctor is present when the injection is administered in the chart so that the services are easily audited and supported.

Please note that allergy testing services do not fall under incident to. Instead, they fall under the rules for the provision for diagnostic services. Although most allergy testing requires the same direct supervision as incident to (meaning the doctor must be in the office), there are some codes that actually require the doctor in the exam room with you (personal supervision).  These tests are rarely performed. It is also a major compliance violation to perform allergy testing without the physician under whom you bill the testing to be present in the office.