Ten Minute Tidbit Variety

1. Ten Minute TidbitVariety Glena Jarboe/ Colleen King Ambulatory Compliance Manager April 2014

2. When to Call Compliance (your DRB) • When you get word of an upcoming audit • When someone with a badge shows up • Email from outside auditing entity (Wellcare, Ingenix, Outcomes, OIG etc…) • Potential Breach • HIPAA concern • Anything you believe in good faith is illegal, unethical or abusive

3. The “incident to” Provisions of Medicare • Services submitted under the physician’s NPI but are actually performed by someone else • “Incident to” applies only to Medicare • Restrictions may apply on types of services that ancillary personnel may perform under this provision • Physician attestation does not equal incident to

4. The “incident to” Provisions of Medicare • Services must be part of the physician’s services to diagnose or treat the injury or illness • Not appropriate for: • New visits • New course of treatment • New problem • Significant change in an established condition

5. Who can provide services “incident to?” continued... • Non-physician practitioners (NPP’s) including nurse practitioners and physician assistants • Nurse practitioners and Physician Assistants may provider services under their own NPI, they may also provider services “incident to” a physician and submit these services under the physician’s NPI, when all requirements are met

6. “Incident to” Summary • Apply to office setting only • Services billed to NPI, but provided by someone else • Billed to physician covering clinic (physically present) • Direct supervision is required • Physician must be physically present in the office suite and immediately available while the service is being provided • Physician not required to be in the same room

7. General Documentation • NPP are required to bill under their own NPI for all carriers except Medicare. • Attesting to documentation (“I saw and examined the patient with the APRN and agree with their assessment and plan”) does not make the encounter billable under the physician NPI

8. Any Questions?  http://www.cms.gov