I know this is a late reply posting, but I must stress caution with the interpretation above.
Time documentation does not apply towards incident to billing. This has been elaborated by many MACS, even if your MAC doesn't specifically state it the interpretation of the guidelines here are concerning.
Your manager is 100% correct regarding....
Counseling by other staff is not considered to be part of the face-to-face physician/patient encounter time. Therefore, the time spent by the other staff is not considered in selecting the appropriate level of service., but you are also correct that a NPP is considered a provider as much as a physician when it comes to billing. But you are twisting the rules to fit your needs when using time documentation.
A physician or other healthcare provider can bill based on time documentation, just not as incident to under the supervising physicians NPI #. This means that the provider doing the face to face work, is the person the claim needs to be billed under their own NPI #. If the PHYSICIAN did not perform face to face work themselves, then the NPP needs to bill under their own NPI number.
CMS Guidelines on Time Documentation:You must appropriately and sufficiently document in the medical record that you personally furnished the direct face-to-face time with the patient specified in the CPT code definitions. Make sure that you document the start and end times of the visit, along with the date of service.
I have heard this statement spoken many times in CMS webinars, but this is the only place I have seen it written.
http://www.cms.gov/Outreach-and-Edu...k-MLN/MLNMattersArticles/downloads/MM5972.pdf
I have billed oncology education encounters for years and they are billed under the NPI's of the NPP's even though it is part of the treatment plan of the oncologist. The billing staff could get a physician in trouble by billing incident to based on an NPP's time documentation and it's just not worth the little extra % to the practice.