Wiki NPP Billing for Procedures in the ICU

[PLDalsoren]

I have a question on who's NPI I should be billing the following scenario under. There is a group of doctors who run the ICU in one of our hospitals. They provide pulmonary and critical care services. The doctors use a number of NPP's to assist in the care of these patients, specifically when it comes to procedures. The doctor said that the NPP will perform the procedure with the doctor standing right next to them supervising the entire time. It is my understanding that this is not a teaching hospital and the NPP's are not students. The doctor is insisting that even though the NPP is the one performing the procedure, he is right there and supervising, therefore we can bill the procedure under the doctor's NPI. All of the research I have done states that if the NPP performs the procedure it should be billed under their own NPI. The doctor is arguing this isn't true. Can anyone advise on what the correct billing guidance would be on this? Thank you!

 

[thomas7331]

I agree with you. It sounds like the doctors are arguing that the NPP's services can be billed 'incident to' the physician since they are supervising the procedures. But 'incident to' billing is not allowed in a facility setting - it applies only to services performed in the physician's own office. This is clearly stated in the Medicare regulations. In the facility setting, all services, with the exception of split/shared E/M services, must be billed by the provider who personally performed the service.

 

[jkyles]

This is just an observation but even if this was appropriate billing (which it isn't, as explained above) doesn't the practice take a financial hit if the doctor stands around watching an NPP work when he could be treating another patient? Instead of 100% for a physician service and 85% for the NPP's, the practice is just getting that 100%.

From an audit/compliance angle, it would be extremely difficult for a practice to get an auditor or investigator to believe it didn't know about or understand incident-to rules. One MAC recently instructed practices to conduct self-audits of their incident-to claims and return any overpayments.

 

[PLDalsoren]

This is just an observation but even if this was appropriate billing (which it isn't, as explained above) doesn't the practice take a financial hit if the doctor stands around watching an NPP work when he could be treating another patient? Instead of 100% for a physician service and 85% for the NPP's, the practice is just getting that 100%.

From an audit/compliance angle, it would be extremely difficult for a practice to get an auditor or investigator to believe it didn't know about or understand incident-to rules. One MAC recently instructed practices to conduct self-audits of their incident-to claims and return any overpayments.

Thank you for your response! I so appreciate it. If the NPP is performing the procedure then the billing would be under the nurse practitioners NPI. How would I bill if there was a situation where the doctor is doing the procedure and the NPP is assisting? Is that a situation where I would bill under the doctors NPI and the NPP's or just the doctor? Also, I want to clarify that incident-to billing has never been allowed in the hospital setting correct? I hope I'm not being a bother. I am the only coder in this practice and I'm still very new to medical coding. I've been doing lots of research on this but sometimes it helps to ask people who are much more experienced than me. Thank you!

 

[jkyles]

Thank you for your response! I so appreciate it. If the NPP is performing the procedure then the billing would be under the nurse practitioners NPI. How would I bill if there was a situation where the doctor is doing the procedure and the NPP is assisting? Is that a situation where I would bill under the doctors NPI and the NPP's or just the doctor? Also, I want to clarify that incident-to billing has never been allowed in the hospital setting correct? I hope I'm not being a bother. I am the only coder in this practice and I'm still very new to medical coding. I've been doing lots of research on this but sometimes it helps to ask people who are much more experienced than me. Thank you!

Hi, For the first question I think it will depend on how much assistance the NPP provides and whether the procedure is normally performed with assistance.

For the second, yes that's 100% correct. It can get confusing because sometimes people will use the term split/shared for incident-to services, but they aren't the same.