Wiki NMD billing as MD

[jenmendoza]

Hello!

I have a quick question: Our practice is intending on bringing an NMD (Naturopathic Doctor) into the practice and have them see patients as their service provider, but have the billing provider listed as an MD. [It's basically two doctors seeing a patient in one visit, with the NMD accompanying the MD, providing both holistic and clinical care]. Is this allowed?

TYIA!

 

[thomas7331]

I am pretty sure that this is not allowed. The NMD credential, as far as I'm aware, is not a provider type that is recognized by CMS as eligible to diagnose patients and/or bill services to Medicare or Medicaid and probably most other insurances as well. In order to bill that provider's services under the MD, all of the services would have to qualify as 'incident to', in other words your NMD would not be practicing independently and would simply be carrying out the orders of the MD, acting basically as a nurse or other staff member carrying out the MD's orders. Anything that they did independently under their own credentials, such as the 'holistic care' you're saying that they would offer, could not be counted toward the MD's work because the only things you can bill under the MD's credentials are those services that the MD initiates in their own plan of care. They could possibly make recommendations to the MD and the MD could then document and order those things in their own care plan, but the NMD's work could not be billed by the MD as a separate service.

I think it's a question that would really be best put to an attorney or compliance specialist to ensure your practice doesn't do anything potentially illegal or noncompliant, but I'd be very careful about doing something like this.

 

[jkyles]

Hello!

I have a quick question: Our practice is intending on bringing an NMD (Naturopathic Doctor) into the practice and have them see patients as their service provider, but have the billing provider listed as an MD. [It's basically two doctors seeing a patient in one visit, with the NMD accompanying the MD, providing both holistic and clinical care]. Is this allowed?

TYIA!

Are they a medical doctor who practices naturopathy or a naturopath? Either way, you need to check your state law and medical board.

 

[jenmendoza]

I am pretty sure that this is not allowed. The NMD credential, as far as I'm aware, is not a provider type that is recognized by CMS as eligible to diagnose patients and/or bill services to Medicare or Medicaid and probably most other insurances as well. In order to bill that provider's services under the MD, all of the services would have to qualify as 'incident to', in other words your NMD would not be practicing independently and would simply be carrying out the orders of the MD, acting basically as a nurse or other staff member carrying out the MD's orders. Anything that they did independently under their own credentials, such as the 'holistic care' you're saying that they would offer, could not be counted toward the MD's work because the only things you can bill under the MD's credentials are those services that the MD initiates in their own plan of care. They could possibly make recommendations to the MD and the MD could then document and order those things in their own care plan, but the NMD's work could not be billed by the MD as a separate service.

I think it's a question that would really be best put to an attorney or compliance specialist to ensure your practice doesn't do anything potentially illegal or noncompliant, but I'd be very careful about doing something like this.

Thank you so much for your response! Yeah... I kinda figured it shouldn't be allowed, especially if the MD had no part in it, unless they were collaborating together during the visit with the MD doing the care plan.

That is true, thank you so much for your insight! ; v ; )

 

[jenmendoza]

Are they a medical doctor who practices naturopathy or a naturopath? Either way, you need to check your state law and medical board.

Thank you for your response! No... they are strictly an NMD. The practice was debating on having an NMD and MD collaborate together during the patient visit and have the MD as the billing provider.

 

[jkyles]

Thank you for your response! No... they are strictly an NMD. The practice was debating on having an NMD and MD collaborate together during the patient visit and have the MD as the billing provider.

Agree with Thomas7331's response and would just add that a system where patients see the NMD separately and pay for those encounters out-of-pocket would probably be safer (and easier).