June 30, 2022
We just recently began hiring PAs to see patient to assist our pain physicians. Our pain doctors want the PAs to see new patients and bill under their NPI number. We see a large population of Medicare patients and I am worried this could get us into trouble.
For Medicare patients if the PA sees a new patient the service must be reported under the PA’s NPI number. In order to bill under the physician’s NPI number the patient must be an established patient with an established plan of care. If the patient has a new problem or worsening problem either it must be billed under the PA’s NPI number, or the physician must see the patient on that date of service. If the criteria is met for incident to also keep in mind the physician must be in the office suite and immediately available but does not be in the room.
We have a debate in or office. Our doctors always bill an E/M service with a procedure in the office. For example we had a patient the other day in which the reason for the visit was a trigger point injection. The physician submitted 99213-25 and 20552 for the trigger point. I am new to this specialty, but I was always instructed that if the reason for the visit is the injection, we can only bill the injection. Which is correct?
When the reason for the visit is the injection and there is not a significant separately identifiable service then only the procedure is reported (20552) Keep in mind there is an inherent E/M service in every procedure. Any discussion or evaluation related to the injection before the procedure would be considered included in the trigger point preservice time of 11 minutes.
*This response is based on the best information available as of 06/30/22