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PLAIDMAN

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Can someone please confirm that a PA cannot bill for a new patient under his/her credentials ?

New patient has to be incident to / billed under Physician ?


thx
 
It is just the opposite. A new patient encounter can never be billed incident to. If the PA sees a new patient it must b billed under the PA NPI. Some states however have "rules" that state a PA is not allowed to see a new patient. That means not even incident to. If the patient is a new patient then there is no way the physician could have had an encounter with the patient to establish a plan of care that the PA is following up on. Those are the parameters for incident to.
 
even more confused

My docs use their PA as an "assistant" - I am told BY the physicians that they (the DR) see/exam every single patient...and that the PA just helps them like an "MA"...the PA will also dictate the note...with a statement saying "patient was seen in presence of DR and all MDM was that of the DR" note is signed by DR.

Majority of these visits are billed under the Physician . It does not seem right to me...

I am very confused as to how I should be billing these?
 
My docs use their PA as an "assistant" - I am told BY the physicians that they (the DR) see/exam every single patient...and that the PA just helps them like an "MA"...the PA will also dictate the note...with a statement saying "patient was seen in presence of DR and all MDM was that of the DR" note is signed by DR.

Majority of these visits are billed under the Physician . It does not seem right to me...

I am very confused as to how I should be billing these?

If this is to be treated as a shared encounter, then it can be established patients only, and the physician must document the portion of the encounter that they provided, not just a signature on the note documented by the PA.
 
An inpatient Split/Shared Evaluation and Management (E/M) service is defined by the Centers for Medicare & Medicaid Services (CMS) IOM Publication 100-04, Chapter 12, Section 30.6.1(B), as an E/M service, "...shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient." Additionally, IOM Publication 100-04, Chapter 12, Section 30.6.13 (H) states that, "A split/shared E/M visit is defined by Medicare Part B payment policy as a medically necessary encounter with a patient where the physician and a qualified NPP each personally perform a substantive portion of an E/M visit face-to-face with the same patient on the same date of service. A substantive portion of an E/M visit involves all or some portion of the history, exam or medical decision making key components of an E/M service."

Both the physician and the NPP must each personally perform part of the visit, and both the physician and the NPP must document the part(s) that he or she personally performed. When the supporting documentation does not demonstrate that the physician "performed a substantive portion of the E/M visit face-to-face with the same patient on the same date of service" as the portion of service performed by the NPP, a service billed under the physician's Provider Transaction Access Number (PTAN) will be denied.

It is of particular importance to remember that notes documented by the NPP for E/M services performed independently within a facility, and later reviewed and co-signed by the physician, depict neither a scribe situation nor an appropriate split/shared visit. Additionally, "incident to" guidelines do not apply to services in an inpatient setting. In this situation, the service should be billed under the NPP's provider number, and would be reimbursed at the established rate for that provider.

With the IOM requirements in mind, the following are examples of medical record documentation by the physician which would not be considered adequate to support a split/shared visit:

"I have personally seen and examined the patient independently, reviewed the PA's Hx, exam and MDM and agree with the assessment and plan as written" signed by the physician
"Patient seen" signed by the physician
"Seen and examined" signed by the physician
"Seen and examined and agree with above (or agree with plan)" signed by the physician
"As above" signed by the physician
Documentation by the NPP stating "The patient was seen and examined by myself and Dr. X., who agrees with the plan" with a co-sign of the note by Dr. X
No comment at all by the physician, or only a physician signature at the end of the note

http://www.wpsmedicare.com/j8macpartb/resources/provider_types/inpatientsplitem.shtml


The answer to your original question is 180 degrees opposite of what you stated. In an office setting New Patient visits that were not seen by a physician can only be billed under the NPI of the Midlevel.

For the sake of clarity please make sure you are not confusing the place of service(s) for Incident To and Shared Split Visits.
 
Last edited:
An inpatient Split/Shared Evaluation and Management (E/M) service is defined by the Centers for Medicare & Medicaid Services (CMS) IOM Publication 100-04, Chapter 12, Section 30.6.1(B), as an E/M service, "...shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient." Additionally, IOM Publication 100-04, Chapter 12, Section 30.6.13 (H) states that, "A split/shared E/M visit is defined by Medicare Part B payment policy as a medically necessary encounter with a patient where the physician and a qualified NPP each personally perform a substantive portion of an E/M visit face-to-face with the same patient on the same date of service. A substantive portion of an E/M visit involves all or some portion of the history, exam or medical decision making key components of an E/M service."

Both the physician and the NPP must each personally perform part of the visit, and both the physician and the NPP must document the part(s) that he or she personally performed. When the supporting documentation does not demonstrate that the physician "performed a substantive portion of the E/M visit face-to-face with the same patient on the same date of service" as the portion of service performed by the NPP, a service billed under the physician's Provider Transaction Access Number (PTAN) will be denied.

It is of particular importance to remember that notes documented by the NPP for E/M services performed independently within a facility, and later reviewed and co-signed by the physician, depict neither a scribe situation nor an appropriate split/shared visit. Additionally, "incident to" guidelines do not apply to services in an inpatient setting. In this situation, the service should be billed under the NPP's provider number, and would be reimbursed at the established rate for that provider.

With the IOM requirements in mind, the following are examples of medical record documentation by the physician which would not be considered adequate to support a split/shared visit:

"I have personally seen and examined the patient independently, reviewed the PA's Hx, exam and MDM and agree with the assessment and plan as written" signed by the physician
"Patient seen" signed by the physician
"Seen and examined" signed by the physician
"Seen and examined and agree with above (or agree with plan)" signed by the physician
"As above" signed by the physician
Documentation by the NPP stating "The patient was seen and examined by myself and Dr. X., who agrees with the plan" with a co-sign of the note by Dr. X
No comment at all by the physician, or only a physician signature at the end of the note

http://www.wpsmedicare.com/j8macpartb/resources/provider_types/inpatientsplitem.shtml


The answer to your original question is 180 degrees opposite of what you stated. In an office setting New Patient visits that were not seen by a physician can only be billed under the NPI of the Midlevel.

For the sake of clarity please make sure you are not confusing the place of service(s) for Incident To and Shared Split Visits.
Shared visits can occur in the office setting as well as long as they meet the incident to requirement. This is from the transmittal CR1776

2. In an office setting the NPP performs a portion of an E/M encounter and the physician completes the E/M service. If the "incident to" requirements are met, the physician reports the service. If the ?incident to? requirements are not met, the service must be reported using the NPP?s UPIN/PIN.
 
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