Practice Management Alert
Incident-To Supervision Requirements
Question: A patient came in to see one of the physicians in our practice. The doctor developed a care plan and asked the patient to come back in one week for re-evaluation. The patient saw our nurse practitioner at that follow-up visit. The physician was not in the office at the time. However, the physician assistant who practices the same specialty as the physician was in the office. Can we bill this service incident-to since the supervising provider works in the same group and specialty as the doctor who developed the care plan? Michigan Subscriber Answer: No, you cannot bill this service as incident-to the physician or the physician assistant (PA). CMS rules say that the supervising provider -- the PA in this case -- must have the same education level as the provider who set up the patient's plan of care. If another physician from the same specialty had been in the office during this visit, you could report the service as incident to the physician who was in the office -- not incident to the physician who set up the plan of care. But because the physician set up the plan of care was not in the office, nor was another physician, and you cannot consider the PA as meeting the supervision requirements, you cannot bill this service as incident to. Best bet: In this case, you should bill the follow-up visit under the nurse practitioner's own national provider identifier (NPI) and expect 85 percent of the full service fee. Tip: Though it is not required (yet), experts recommend that the physician who establishes the care plan include a note approving nonphysician practitioner (NPP) involvement in the patient's care. That way, the patient's record will show the physician's active participation in the management of the patient's course of treatment. Example: During the initial visit to treat a patient's hypertension, an internist includes a note stating: -Established care plan for patient's hypertension; visits to NPP for follow-up care approved.- Tell your physicians to get in the habit of writing these linkage notes, because down the road payers will likely require this step.
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