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January 6, 2012

Billing for Non Physician Practitioner Services

If you are in charge of billing for non physician practitioners in your office group, you may be billing erroneously. It is important to bill services of non physician practitioners (NPP) under the correct Provider Transaction Number (PTAN). Evaluation and Management (E/M) services performed in the office setting by the NPP can be billed to the physician's PTAN as "incident to" if the patient is an established patient and the requirements of "incident to" are met.

Services of NPPs who provide E/M services in an institutional setting, including hospitals and nursing facility settings, must be billed to the NPP's PTAN unless the visit meets the requirements of the split/shared visit. Split/shared visits may be billed to the physician's PTAN as long as the NPP and physician are employed by the same employer or are in the same group practice. The physician MUST have a verifiable and significant face to face encounter with the patient on the same day as the visit by the NPP. This encounter must consist of more than a review of the medical record by the physician. Attention to detail of proper billing cannot be stressed enough.

AdvanceMed is tasked with data mining to identify aberrant, and potentially fraudulent, billing patterns. Analysis has found an increase in the number of providers whose data demonstrates the physician is working up to, or more than, 24 hours per day. 

After investigation by AdvanceMed, and many hours of physician and/or their office staff time, it was determined the issue was incorrect billing of NPP services under the physician PTAN.  Billing under the correct rendering practitioner PTAN can potentially avoid costly and resource intensive audits caused by inflated data. 

Resources: Medicare Benefit Policy-Basic Coverage Rules (Pub. 100-02) Chapter 15 Sections 60.1; 60.2; 60.3

Medicare claims processing Manual (Pub. 100-04) Chapter 12, Section 30.6.1B

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