This article has been filed under the New Practice Start Up category because it is an important part of many private practices.
If you are utilizing mid-levels in your practice or plan to in the near future, it is imperative that you and your billing staff understand how to charge Medicare and other payers for your mid-level’s services.
The Centers for Medicare and Medicaid (CMS) defines incident-to services as those that are “furnished incident to physician professional services in the physician’s office (whether located within a different office suite or within an organization) or in the patient’s home.
There are essentially two ways that a practice can bill for mid-level services:
- Under the mid-level’s identification number, or
- “Incident-to” the physicians care and billed under the physician’s provider number, just as if the physician had rendered the service.
If billed under the physician, your practice will be reimbursed at 100% of your normal fee schedule. Reimbursement drops to 85% if the service is billed under the mid-level’s provider number.
With that being said it’s obvious its more favorable to your practice to bill “incident-to” but in order to do so you must meet these requirements:
- The mid-level, whether full-time, part-time, an independent contractor or a leased employee must answer to a physician in your practice.
- A physician must initially see the patient and establish a plan o of care.
- The services rendered by your mid-level are typically offered in your office and are part of your documented treatment plan.
- The physician is on-site – not necessarily in the same room, but in the same office – when the mid-level sees the patient so that the physician is readily available to provide assistance if necessary-It is worth noting that states have their own indirect and direct supervision laws regarding the use of Midlevel practitioners in private practice.
- The physician must continue to be actively involved in the patient’s plan of care.
Some private payers have their own incident-to requirements. Most are in line with Medicare, but some do follow their very own specific protocols, while others offer some leeway. The key is to check with your major payers and follow their guidelines.
Some commercial payers will not credential directly with PAs and NPs, which means you can’t bill under the midlevel’s provider number. In such instances, make sure and follow the rules for incident-to billing. Under such circumstances, some payers just instruct the practice to bill all services under the provider number of the credentialed physician.
The documentation in the patient chart must match the service that was billed. Physicians should be sure that the chart note specifies that he was in the suite and available to assist when the service was rendered.
Author: Dallas Alford
Article Source: EzineArticles.com
