Pulmonology Coding Alert

Question: How do you report a consultation performed by a nonphysician practitioner (NPP) on a hospital inpatient?

Arizona Subscriber

Answer: The key is reporting the inpatient consultation location. Medicare allows you to report Part B (physician) services that the NPP provides in a hospital as long as you don't report the services "incident to" (meaning under the physician's national provider identifier [NPI]). You may only report incident to services in the physician's office and not in a facility-based setting (an outpatient hospital or an inpatient facility).

Therefore, if your NPP provides a consult in the hospital and documents the "three R's" of the consultation (request, review, and report back to the requesting physician or proper notation in the shared record), you can report the appropriate consult code (99251-99255) under the NPP's NPI.

Watch out: Because a consultation involves evaluat-ing a new problem, an NPP may never provide this service incident to and must always provide consultations only under his own NPI, even if provided in a physician's office. Additionally, inpatient consults cannot be shared/ split. The billing provider (physician or NPP) must provide a complete service and report the service under his own NPI.

Mind Medicare: You may have to document the supervision requirements for some no-Medicare insurers. Check with your payers before you set up practices for the NPPs. Check your state and hospital scope-of-practice guidelines before you bill an NPP's consult. State guidelines can vary.