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Medical Management Associates, Inc.
Ask-A-Consultant: Incident-to Billing for NPP services
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Date: 02/25/2004
Q:
What are the requirements for incident-to billing for NPP services for prenatal care in the office? What are the physician's obligations in this situation?
Washington, DC
A:
For Medicare purposes, the incident-to billing guidelines are the same for all providers regardless of specialty and are as follows:
- The services must be provided by an employee of the physician/practice (employee may be contracted);
- The services may only be provided to established patients. If an established patient presents with a new problem, the physician must see the patient and establish a plan of care for the new problem;
- The services must be provided in the office and must be incidental to the physician's services;
- The physician must be in the office suite and immediately available and must provide personal services of appropriate frequency to indicate involvement in the patient's care; and
- The physician must sign NPP's notes to indicate care provided was appropriate.
However, patients receiving prenatal care are more likely to be insured by private payors, which may or may not follow Medicare's incident-to guidelines. State laws may also have more stringent requirements for supervision and signatures. Therefore, it is important to obtain policies from your top payors and to review your state's laws with regard to the medical profession.
Bottom line, it is the physician's responsibility to provide personal services in the event there are any complications during the pre-natal period and to ensure the NPP is qualified to provide pre-natal care. Above all, remember that the physician is ultimately responsible for all incident-to services provided, so, for risk management and quality of care purposes, it is in his/her best interest to appropriately supervise all NPP providers.
Mary Beth Black, CPC
Senior Associate
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