Wiki Another "incident-to" ?

lnaschke

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We are a multi-specialty group which employs 12 APN and 1 PA. We cannot bill incident-to for most of their visits because 1.) the physician does not always initially see the patient, and, 2.) the physician does not necessarily play an active part in the ongoing care of the patient. That said, my medical director wants me to find information on supervisory billing and the only thing I have found so far pertains to attending physicians for residents. I do not believe we can do this, but my supervisor, who has never worked in health care before says that until I can show her written guidelines stating that we cannot bill our APN visits under the supervising physicians, we will continue that practice.

Does anyone have a "go-to" website that I can visit and get printed guidelines about this issue?

thanks
Laura
 
You stated that the physician "does not always initially see the patient"...and, 2.) the physician does not necessarily play an active part in the ongoing care of the patient.

Who initially see's the patient? Who establishes and maintains the plan of care? Are your midlevels credentialed with the Medicare program? If so...you would file those type of claims under the midlevels NPI number. However...if they (midlevels) aren't credentialed with Medicare...the provider MUST see the patient's initially and establish the plan of care as well as staying active in that plan of treatment.

http://www.cms.hhs.gov/mlnmattersarticles/downloads/se0441.pdf
 
http://oig.hhs.gov/oei/reports/oei-09-06-00430.pdf

I hope you have a compliance officer that has experience in healthcare. Your medical director has the wrong attitude, money is important but in this day and age compliance should come first. You can get paid for just about anything if you bill it in a way that is covered. If you can't support your bills with documentation that money goes back multiple times over, plus fines, plus risk of jail time and exclusion from government programs.

I feel your pain,

Laura, CPC, CEMC
 
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