Wiki Need Opionion on Shared Services

[klamm]

I would like to get a second opinion on whether or not this is enough documentation to code under the physician's NPI? The NP provided a very detailed note and stated that she and the doctor both saw the patient.

"I personally saw and examined the patient with ARNP in heme onc div. Please review her note for complete details.
Patient has been diagnosed with metastatic gastric cancer and agreed to proceed with therapy.
Also plan to do PRN paracentesis for malignancy ascites."

Thanks
KJLamm, CPC

 

[thomas7331]

In a hospital setting, this would meet the requirements to bill under the physician's NPI as a split/shared service since the physician has provided a face-to-face portion of the E/M encounter. But in an office setting, it would need to be an established patient and meet all of the other 'incident to' requirements, which is hard to tell without seeing the NP note. If in the office, and if it is a new patient or if the NP is initiating or making changes to the care plan at this encounter, then it would not qualify as 'incident to' and should be billed under the NP's NPI.

 

[klamm]

The patient is established with the clinic but the diagnosis is new and treatment is being initiated during this visit. The physician stating that patient agrees with therapy and paracentesis is not sufficient?

Thanks
KJLamm, CPC

 

[thomas7331]

As I understand it, this is not sufficient. 'Incident to' services, by definition, are those services that are initiated and/or ordered by a physician but carried out by his or her employees. The CMS language is that in order to "qualify as “incident to,” services must be part of your patient’s normal course of treatment, during which a physician personally performed an initial service". If the NP initiated the course of treatment, then this is a NP service, not a service that the physician ordered as part of the plan of care, therefore not 'incident to' the physician. The fact that the physician as reviewed it and agrees with may be part of their responsibility for supervision of an employee, but does not qualify the NP's work to be billed as a physician's work, so to speak.