I am having a hard time locating information on what documentation requirements are needed, in the office note, to support Incident-to?
We have NPP's who perform follow-up visits, once a plan of care is established by our Dr's. However, we are not clear what is needed to be reported in the notes, to establish that when the NPP see's the pt (the NPP does the note & signs the note), but the claim goes out w/ the Dr's name & NPI.. is there anything specific that needs documented in the note?
thanks!
First thing is should you be doing incident to. There are two views on incident to:
1. The physician establishes the plan of care and then is followed by the APP (PA or NP). For example: Hypertension - I will start the patient on Amlodipine the patient will follow up for further titration.
2. The physician establishes the plan of care which must be exactly followed by the APP. For example: Hypertension - I will start the patient on Amlodipine titrate to 10 mg for SBP < 120 if the patient still has SBP > 120 I will add captopril and titrate to x mgs etc.
For one if the patient needs a second drug then its up to the APP to decide. For the second lets say the patient has a reaction to captopril and needs another agent. Then either they return to the physician for further plan or have the APP develop the plan and be reimbursed at 85%.
Strictly reading the regs I tend to think the second interpretation is correct. You should defer to your MAC for guidance on this.
The next part is to make sure that you are following all other rules for incident to. Is the physician (or one of the other physician partners) present in the suite of offices - this means immediately adjacent not on another floor or in the hospital that is connected y a bridge. If they are at lunch for example then no incident to.
Does the patient have another new problem. Then the whole visit has to be sent to the physician for a new plan. Otherwise the problem can't be billed under incident to. For example a patient with hypertension - the APP notices the patient has elevated cholesterol. They can start the patient on a statin and bill at 85% or send the patient back to the physician for a new plan - meaning another office visit for the patient or an interruption for the physician's schedule.
Finally you have to show ongoing physician involvement. Many MACs interpret this as regularly scheduled visits with the physician.
A lot of compliance offices think that given the problems with incident to it's not worth the risk.