Non-Physician Practitioners or Mid Level Providers are eligible to provide all types of visits that a physician provides. Although rules for coding are same for both, but payment is 85 percent of the payment for physicians from Medicare. Non-physician practitioners include Nurse Practitioners, Physician’s Assistants, and Clinical Nurse Specialists. By involving NPPs in daily practice, physicians are able to dedicate themselves to their best uses while improving quality of care and strengthening practice revenue. Physicians often work with NPPs in two ways. One is Incident-To, another one is shared visits.
Incident-to services must be an integral although incidental part of the physician’s personal professional services the patient’s treatment program. These services allow the physician to bill for services provided by non-physician practitioners, supervised by that physician at the full MPFS rate, as if he personally performed the service. But for these reimbursement benefits, the services must meet certain requirements. These services must be performed under direct supervision of the Physician which means that the physician must be physically present in the office and immediately available to provide assistance and direction when the service is performed. However, Physicians cannot use incident-to billing when more than 50 percent of the service is counseling or coordination of care billed on the basis of time spent with the patient. Remember that, diagnostic tests may never be billed incident-to.
A shared visit is performed partly by the non-physician practitioners and partly by the physician under which the service is reported. In a shared visit, the physician performs an E/M service, including face-to-face time with the patient, but “shares” the visit with an non-physician practitioners who also works in the physician’s group. In this way, sharing visits allows physicians to provide more services, both in and out of a hospital setting, and reduces the amount of time invested. However, CMS has not yet specified any rule regarding which portions of the service each one must provide. Till date combined documentation is used to support the reported code.
So to conclude at the end, bill for incident-to when the non-physician practitioners performed all the services, and for shared services when the visit was shared by the NPP and the physician. But as we know, for proper billing the key factor is documentation. To prevent claim denials, make sure all required elements are present in the documentation before billing.
While billing for shared services, these two key elements must be present in the visit record:
- Documentation of the face-to-face portion of the E/M visit; and
- There should be clear differentiation of services performed by NPP and services performed by Physician.
More importantly, not only the documentation should clearly state who performed which services, but the NPP must be the one to document the services he/she performed and the physician must do the same.