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Practice Page

Staff  |  Issue: May 2011  |  May 16, 2011

Incident-To: What Are The Guidelines?

In today’s busy medical practice, many rheumatologists are utilizing the services of nonphysician healthcare professionals such as nurse practitioners (NPs), physician assistants (PAs), clinical nurse specialists, certified nurse midwives, occupational therapists, and medical technologists. Rheumatology practices typically employ the services of NPs and PAs to assist with the overall patient flow. Having an NP or PA can be a great time saver and a revenue booster to rheumatology practices because this will create time to accept new patients. But, as with all things concerning coding and billing, there are certain guidelines that practices must adhere to when billing for the services of NPs and PAs, mainly when using the Medicare payor system.

Medicare allows physician practices to bill for the services of nonphysician providers, and these services are known as “incident-to.”   The Medicare benefit policy manual defines incident-to as “services furnished as an integral although incidental part of a physician’s personal professional service.” Nonphysician providers can bill incident-to services under the supervising physician’s name and national provider identifier number for reimbursement at 100% of the Medicare fee schedule.

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In order for a nonphysician provider to bill incident-to for Medicare patients, these specific guidelines must be followed:

  • The service must be performed in the physician’s office;
  • The physician must be in the office suite at the time of the service;
  • The nonphysician provider can only see established patients with established diagnoses; and
  • The service must be in the scope of practice of the nonphysician provider.

If the above rules are not met, the nonphysician provider can still perform the service but would not be reimbursed as incident-to. The service would have to be billed under the nonphysician provider’s National Provider Identifier (NPI) number and reimbursed at 85% of the Medicare fee schedule.

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As demonstrated above, there are specific criteria that must be met to employ a nonphysician provider. Here are some answers to frequently asked questions about using the services of NPs and PAs.

  • Can a nonphysician provider see a patient, new or established, if there is no physician on site?
    • Yes, the services would have to be billed under the nonphysician provider’s NPI number, and the services would be reimbursed at 85% of the Medicare fee schedule.
  • Can a nonphysician provider see a patient that has private insurance?
    • Each private insurance carrier will have its own specific guidelines on whether it would reimburse services performed by nonphysician providers. Physician practices should call to verify if services delivered by a nonphysician provider are covered under the patient’s policy.
  • What happens if an established patients presents with a new problem during the visit with a nonphysician provider?
    • Either the visit can continue and it will have to be billed out under the nonphysician provider’s provider number; or
    • The visit must be suspended and the physician has to take over the visit. The physician must take the patient history of present illness, perform the exam, and make his or her own medical assessment.
      • It is not permissible to have the physician only read over the NP’s notes and make a medical decision on the nonphysician provider’s findings. This is considered to be a shared or split visit.

The partnership of physicians and nonphysician providers can bring successful financial benefits to rheumatology practices if the guidelines are followed. Remember, the rules for nonphysician providers are very specific for Medicare carriers but practices will have to contact private carriers for their guidelines for these types of providers. Nonphysician providers can be a great economic asset to a rheumatology practice if all the coding and billing guidelines are followed.

If you have questions about coding or billing for nonphysician providers, contact Melesia Tillman, CPC, CRHC, CHA, at (404) 633-3777 ext. 820 or [email protected].

New Practice Management Books

The ACR has published two new e-books to assist ACR and ARHP members with practice management: The Business Side of Rheumatology and Rheumatology Coding Manual. These reference guides can be viewed online or downloaded to keep in office. Visit www.rheumatology.org/publications to get your copies today.

Managing Patient Payments

Medical bills are one of the most common unpaid debts for consumers. A McKinsey Quarterly report stated that 50% of every dollar billed to patients goes uncollected—an estimated $65 billion in uncollected revenue in 2010! The number of uninsured Americans plays a pivotal role in this issue. To help alleviate the burden on your practice, have a variety of payment options available for your patients to keep the revenue stream flowing.

Be proactive and collect payment at the point of service, if you don’t already do so. Here are a few tips to improve revenue through the collections process:

  1. Create a payment policy that is fair and flexible to meet the needs of all patients. Communicate the policy through various mediums—on paper, your website, signs posted in the waiting room, and check in/out forms.
  2. Give patients the opportunity to pay as little or as much on their balance as they want at any time. Set up online payment options to make payment convenient.
  3. Allow patients in financial difficulty to design the terms of their payment plan. Accept this in writing, and hold the patient to it.
  4. Train staff to firmly but gently communicate with patients about their financial responsibility.
  5. Provide a monthly payment coupon book for patients that are on a payment plan.
  6. Ask patients to pay a minimum on old balances as well as current charges at time of service.

The main point is to ensure that your practice maintains a healthy and consistent cash flow. Consistent enforcement of your policies and procedures is key.

If you have questions related to practice management, contact the ACR’s practice management department at (404) 633-3777 or [email protected].

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Filed under:From the CollegePractice SupportQuality Assurance/Improvement Tagged with:Billing & Codingnurse practitionerphysician assistantPractice Managementrheumatologist

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