Practice Management Alert

A visit may lose its incident-to status if the PA or NP discovers a new problem

If you have a physician assistant (PA) or nurse practitioner (NP) working alongside the physicians in your practice, you need to be sure you're always billing under the correct provider identification (ID) number.

Not only that, but some third-party payers do not recognize PA or NPID numbers, and require you to bill your nonphysician services another way, says Patricia Trites, MPA, CHBC, CPC, CHCC, CHCO, CEO of Healthcare Compliance Resources in Augusta, Mich. You need to be aware of your different payer requirements, as well as the "incident-to" billing rules, she advises. Follow these expert tips for flawless billing of your PA's and NP's services:

-- Bill under the physician's ID number if the visit meets all the incident-to rules: if the physician is on-site and available and if the PA or NP sees a patient who is already established under the physician's plan of care

-- Use the ID number of the supervising physician who is on-site and available on the date of service. This doesn't necessarily have to be the same physician who started the patient's care, Trites explains.

Using the ID of the on-duty supervising physician makes more sense in terms of billing compliance. If a carrier reviews your scheduling records and sees that you billed services under a physician who was on vacation or out of the office, that could spark an audit, she says.

Remember: The supervising physician is the physician on-site and available on the date of service, not the physician who previously supervised the patient's care plan. "If there are multiple physicians on-site and available," you should use the ID number of the physician who initiated the patient's care, if he is present, Trites says.

-- Bill under the PA's or NP's ID number if the visit doesn't meet all the incident-to rules: if there is no supervising physician on-site or if a new patient presents who is not already under the physician's plan of care. See "Incident-to" Billing Review at right.

-- Report treatment for a new problem under the PA's or NP's ID number. If the physician establishes a patient's plan of care but the patient presents with a new problem and only the PA or NP renders treatment, this visit does not meet incident-to billing requirements, Trites says.

-- Beware a split-billing problem when the PA or NP treats an established problem under incident-to rules but a new problem arises during the course of the visit. Once the PA or NP begins treating the new problem that has no previously established care plan, the visit loses its incident-to status, Trites says. Unless an on-site physician enters the picture and helps to treat the patient's new problem, you must bill the visit under the PA's or NP's ID number, she adds.

1. If your PA or NP does not have his own ID number to bill Medicare, you may not be able to bill his service at all. If a visit doesn't meet incident-to criteria and the PA or NP doesn't have his own number, "then you don't have a claim," Trites says. The only way to avoid this situation is to make sure your PA or NP doesn't see patients outside the incident-to guidelines.

2. Some third-party payers don't recognize PA or NPID numbers. You'll need to check with each of these payers individually to see how they would like you to bill your non-physician services. "You need to know what each of your contracts" dictates for nonphysician payment, Trites says. There's usually always a way to get paid for these services, it just may not include standard billing procedure.

You can bill under the physician's ID number for services a physician assistant (PA) or nurse practitioner (NP) provides "incident-to" the physician's services when:

1. The physician is present and available in the office when the PAor NP sees the patient,

2. The patient is established under the physician's plan of care, and

3. The physician's office is the location where the PA or NP treats the patient.