Transmittal 1776 regarding the Medicare Carriers Manual, Part 3-Claims Process
On October 25, 2002, the Centers for Medicare and Medicaid Services (CMS) issued Transmittal 1776 regarding the Medicare Carriers Manual, Part 3-Claims Process, which states, under the heading "Selection of Level of Evaluation and Management Service:
Office/Clinic Setting -- In the office/clinic setting when the physician performs the E/M service the service must be reported using the physician's UPIN/PIN. When an E/M service is a shared/split encounter between a physician and a non-physician practitioner (NP, PA, CNS or CNM ) 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 UPIN/PIN, and payment will be made at the appropriate physician fee schedule payment.
Hospital Inpatient/Outpatient/Emergency Department Setting -- When a hospital inpatient/hospital outpatient or emergency department E/M is shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient, the service may be billed under either the physician's or the NPP's UPIN/PIN number. However, if there was no face-to-face encounter between the patient and the physician (e.g., even if the physician participated in the service by only reviewing the patient's medical record) then the service may only be billed under the NPP's UPIN/PIN. Payment will be made at the appropriate physician fee schedule rate based on the UPIN/PIN entered on the claim.
Examples of shared visits:
1. If the NPP sees a hospital inpatient in the morning and the physician follows with a later face-to-face visit with the patient on the same day, the physician or the NPP may report the service.
2. In an office setting the NPP performs a portion of an E/M encounter and the physician completes the E/M service. If the "incident to" requirements are met, the physician reports the service. If the "incident to" requirements are not met, the service must be reported using the NPP's UPIN/PIN.
This was reported in the December 2002 issue of The Green Sheet, a monthly newsletter for NPs on compensation issues. To order a 12-month subscription to the newsletter, send a check for $35 made out to "Law Office of Carolyn Buppert," your name and address and a note that you want The Green Sheet to the office at 1419 Forest Drive, Suite 205, Annapolis, MD 21403. For more information on publications addressing legal issues affecting NPs, visit www.buppert.com.
This tip comes from The Gold Sheet, a monthly newsletter addressing quality
issues for nurse practitioners, published by the Law Office of Carolyn
Buppert. To purchase a 12-month subscription, send a check for $35 to Law
Office of Carolyn Buppert, 1419 Forest Dr., Suite 205, Annapolis, MD 21403.
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Last updated: December 31, 2002
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