The health care workforce is changing, as Non-Physician Practitioners (NPPS), or “Physician Extenders” are providing more services. NPPS fall into 2 broad categories: Physician Assistants (PAs) and Advanced Practice Nurses (APNs or ARNP’s).
Since 1998, designated NPPs are allowed to submit Medicare Part B claims for services, including procedures, provided in any inpatient or outpatient setting. For billing purposes, these “independent” services do not require physician involvement (e.g. physician initiation of care plan, physician-patient encounter, or physician presence on patient floor/unit) unless otherwise specified by state legislation or facility standards of practice. NPPs do not need to be employed by the physician group. The entity employing the physician group also may employ the NPP.
Medicare requires that a PA work a Physician Supervisor who provides both management and direction of the PAs activities. This physician need not be present (although some states may require that) but must be available at all times.
The carrier or A/B MAC will pay for PA services at the lesser of the actual charge or 85 percent of the Medicare Physician Fee Schedule (MPFS). PA assistant-at-surgery services are paid to the employer of the PA by the carrier or A/B MAC at 85 percent of 16 percent of the MPFS.
Advanced Nurse Practitioners
ANPs include Certified Mid Wives, Nurse Practitioners, Certified Nurse Anesthetists, and Clinical Specialists. All 50 states allow ANPs to prescribe medications, while some states allow them to practice independent of a physician. In general, the NP is paid for covered services at 85 percent of the Medicare Physician Fee Schedule.
Split/Shared E/M Service
In the office/clinic setting when the physician performs the E/M service, the service must be reported using the physician’s NPI. When an E/M service is a shared/split encounter between a physician and an NPP, the service is considered to have been performed incident to if the requirements for incident to are met and the patient is an established patient. If incident to requirements are not met for the shared/split E/M service, the service must be billed under the NPP’s NPI, and payment will be made at the appropriate MPFS payment.
Since services of Physician Extenders are delivered in a variety of settings, (clinics, nursing homes, patient homes, hospitals, etc.) mobile charge capture systems are imperative, utilizing devices such as phones or tablets. Such programs integrate the CPT and ICD 9 codes and other useful information into one application, allowing the practitioner not only to record medical evaluations, prescriptions, treatments, etc., but also to capture and code the visit enabling an immediate billing.