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Reassignment by Nonphysician Practitioners
The purpose of this article is to clarify the reassignment exceptions, particularly locum tenens and reciprocal billing, as they apply to nonphysician practitioners. Because this is a national policy and providers are responsible for knowing the rules and regulations that apply to all services they bill to the Medicare program, claims received by this carrier that do not meet the provisions of this article will be denied.
Permissible exceptions to the reassignment prohibition are covered in section 1842(b)(6) of the Social Security Act. Section 1842(b)(6)(D) states that billing for substitute services may be done by a "physician for physician services furnished by a second physician to patients of the first physician." This provision contrasts with the other reassignment exceptions, which refer to a "physician or other person."
Accordingly, services of nonphysician practitioners [e.g., Certified Nurse Midwives (CNMs), Certified Registered Nurse Anesthesists (CRNAs), Anesthesia Assistant (AAs), Nurse Practitioners (NPs), Independent Physical Therapists (IPTs), Independent Occupational Therapists (IOTs), Independent Billing Psychologists, Clinical Psychologists (CPs), Clinical Social Workers (CSWs), Clinical Nurse Specialists (CNSs), and Physician Assistants (PAs)] may not be billed under the locum tenens or reciprocal billing reassignment exceptions. These provisions apply only to physicians, as defined in 1861(r) of the Act.
Please also note that the Internet-Only Manual (IOM) 100-04, Chapter 1, Section 30.2.9Adobe Portable Document Format permits a physician or medical group to bill for purchased diagnostic tests; however, nonphysician practitioners may not bill for purchased diagnostic tests. Conversely, a test supplier may not bill for a purchased interpretation, unless the interpretation is done by a physician or medical group. Reassignment of nonphysician practitioner services is permitted under the following exceptions:
Payment to employer
Payment to an agent