Answered by Slava Kurdov, CPC, Billing Department account representative:
Yes, Medicare allows supervised employees (such as nurse practitioners) to submit claims under a physician’s provider number as long as several terms and conditions are met. More importantly, in such cases nurse practitioners (NPs) are reimbursed 100% of the physician’s Medicare fee schedule rate. If an NP and a physician work together to provide physician services, the services can be billed under the physician’s provider number to get the full physician fee, under the Medicare provision for “incident-to billing”. The following aspects must be in place:
1. The services rendered by an NP are an integral, although incidental, part of the physician’s professional service.
2. The services are of a type frequently furnished in physician’s offices or clinics.
3. The services are furnished under the physician’s direct personal supervision and are furnished by the physician or by an individual who is an employee or independent contractor of the physician. Direct supervision does not require the physician’s presence in the same room, but the physician must be present in the same office suite and immediately available.
4. The physician must perform the initial service and subsequent services of a frequency that reflects his or her active participation in the management of the course of treatment.
As it can be understood from the last point, an initial evaluation can only be performed by a physician, and only a physician can assign an appropriate care plan. Nurse practitioners cannot assign a new treatment course for an illness that is not related to an initial clinical condition. For example, if an initial complaint reported by the patient is neck pain, but at some point, during the treatment course, the patient reports hypertension, a nurse practitioner cannot develop a new treatment plan for hypertension.
Most Medicare Advantage plans cover such “incident-to” services.
Please be advised that all services, including those rendered by nurse practitioners, must be medically necessary, and their medical necessity must be clearly indicated in a patient’s medical records. Any deviation from the current billing and documentation guidelines is illegal and punishable by law.