Practice Management Alert

Question: What evidence or documentation do we need to prove the supervising physician was in the office when we reported incident-to services?

Arizona Subscriber Answer: Have your physicians save all personal calendars to prevent frantic scrambling in the event of an audit. If no other records are available, auditors may ask to see the physician's personal planner and calendar to verify he was in the office suite when he claimed to be.
 
You should also make a point to keep old appointment schedules and calendars when you close out billing at the end of the year - these documents can also provide valuable proof. If your software erases scheduling information at the end of the year, ask your vendor to create a backup.
 
Bright idea: One way to preserve scheduling information and prove the doctor was able to supervise a nonphysician practitioner (NPP) on a particular date is to have the billing department batch all information together each day. If you staple a copy of the day's schedule onto each batch of superbills, you can easily retrieve that information when the need arises. Also save sign-in sheets that prove a physician came in on a particular day.
 
Aside from auditors, you should also save scheduling information because you never know when a patient will file a frivolous lawsuit and try to claim the physician wasn't present on a particular date when an NPP treated him.
 
Reason: You must have solid proof your physician was on the premises supervising the NPP to protect your incident-to claims in the event of an audit. For example, if auditors find records showing your physician was actually at the hospital during the time you reported incident-to services, you could have to refund the entire day's worth of incident-to claims.
 
Each carrier has its own guidelines on how to demonstrate that the physician was in the office suite during an incident-to service. Trailblazer, for instance, requires the physician to   sign off personally on all incident-to services. Cigna, on the other hand, doesn't require a signature. And many carriers don't require any positive proof that the doctor was on-site.

 - The answers to the Reader Questions were provided and/or reviewed by Catherine Brink, CMM, CPC, president of HealthCare Resource Management Inc. in Spring Lake, N.J.