March 29, 2018

Question:
We have added a PA to the practice and want to make sure we are using him to the fullest capacity.  We were told that he can see Medicare patients and we can bill it under our physician and get paid at the full fee schedule rate.  Is this true?

Answer:
It depends.  Medicare has Incident-to guidelines that allow NPPs to see patients and bill under the physician’s NPI number and get paid at the full fee schedule rate.  According to the guidelines, in order to bill a visit under the Incident-to guidelines, the physician would have to have seen the patient first and developed a treatment plan that the NPP is following.  The physician also has to be in the office suite (not doing rounds at the hospital) when the patient is being seen.  Finally, the documentation has to show that there is continued involvement of the physician in the patient’s care.  If those criteria are met, the visit may be billed as Incident-to the physician and be paid at the full fee schedule.  So, an NPP cannot see new patients or established patients with new problems and bill them as incident-to visits, but can bill them under their own NPI number and be paid at the 85% rate.  KZA recommends that the physician countersign the notes when an NPP sees a patient as incident-to.  That will prove they were in the office suite and that they have continued involvement in the patient’s care.

*This response is based on the best information available as of 03/29/18.