Medicare Blog

incident to billing how much does an np get reimbursed for a medicare patient

by Arthur Brakus Published 2 years ago Updated 1 year ago

Medicare reimburses NPs at a rate of 85% of the physician fee, as stated in Medicare's Physician Fee Schedule. So, Medicare pays the NP 80% of the 85% of the Physician Fee Schedule rate for a procedure. The total amount that the practice receives is the Medicare payment plus the patient's payment.Apr 7, 2020

Can I Bill a NP as an incident to a doctor?

An NP's services (other than “incident to” services) are reimbursed at 85 percent of the amount shown on the participating physician fee schedule. Note that …

How do NPS bill Medicare?

The Medicare rates for NPs are 85% until it is changed on a federal level. Most Medicare advantage plans (in my experience) follow the Medicare allowable for your location, with a 15% discount for NPs and PAs. I have never contracted with Kaiser Medicare, you would have to contact them and find out what their current practice is.

How does incident-to billing affect Medicare enrollment?

Second, the Medicare reimbursement for an NPP is 85% of the physician’s payment; therefore, physicians understandably want to bill the NPP’s services as incident to their own so as not to lose 15% of their charges.

Can a nonphysician provider Bill incident-to for Medicare?

PAs and NPs can bill under their own names and receive 85 percent of the Medicare physician fee schedule (MPFS) rate. Physicians often work with NPPs on …

How are NPs reimbursed?

States reimburse nurse practitioners at anywhere from 75% to 100% of the physician rate. This means that unlike Medicare, some state Medicaid plans treat services provided by nurse practitioners equally to those provided by physicians. In fact, most states reimburse NPs at 100% the rate of MDs.

Can nurse practitioners bill Medicare directly?

NPs are allowed either to bill Medicare directly under their own provider numbers or to reassign their billing rights to employers or other contracting entities.

When an NP is billing under their own NPI number what is the percentage of reimbursement with Medicare?

While NPs and PAs are permitted to see Medicare beneficiaries for new problems without direct supervision (if permitted under state law) those services must be billed under the NP's or PA's own NPI number – at the 85% reimbursement rate.Mar 29, 2021

When billing for Medicare patients what is the advantage of incident to billing?

The advantage is that, under Medicare rules, covered services provided by non-physician providers (NPPs) are typically are reimbursed at 85 percent of the fee schedule amount, whereas, services properly reported incident to are reimbursed at 100 percent of the full fee schedule value.

Why are nurse practitioners reimbursed less?

Why do NPs get reimbursed less than medical doctors for the same care? The 85% reimbursement policy is supported by the rationale that physicians have higher student loans, pay practice overhead cost, have higher malpractice premiums, and care for more complex patients (MedPAC, 2002).May 31, 2021

How does an NP bill Medicare?

Medicare reimburses NPs at a rate of 85% of the physician fee, as stated in Medicare's Physician Fee Schedule. So, Medicare pays the NP 80% of the 85% of the Physician Fee Schedule rate for a procedure. The total amount that the practice receives is the Medicare payment plus the patient's payment.Apr 7, 2020

Can a nurse practitioner bill a 99214?

Yes, NPs can bill for 99214 and 99215 visits with the following caution: Beware in states where the scope of NP practice is not specifically defined to include comprehensive evaluations.

Can NPs bill for services?

To date, no province or territory has assigned NPs individual billing numbers in order for them to directly bill any public health insurance plan for the insured health services they provide to their patients. As a result, NPs are usually paid on a salary basis.

What is NP modifier?

Medicare has established the -AS modifier to report Physician Assistant (PA), Nurse Practitioner (NP), or Clinical Nurse Specialist (CNS) services for assistant-at-surgery, non-team member.Aug 10, 2021

What does incident to billing mean for the NP?

“Incident to” is a Medicare billing provision that allows a patient seen exclusively by a PA to be billed under the physician's name if certain strict criteria are met.Jun 17, 2019

What is an example of incident to billing?

For example, if the physicians in a group are at the office until noon but then all go to do rounds, the nonphysician providers' services may be billed incident-to a physician until noon and on their own numbers thereafter.

What is incident to billing mean?

Incident-to billing is a way of billing outpatient services (rendered in a physician's office located in a separate office or in an institution, or in a patient's home) provided by a non-physician practitioner (NPP) such as a nurse practitioner (NP), physician assistant (PA), or other non-physician provider.Apr 24, 2014

How much does a nurse practitioner get reimbursed?

Nurse practitioners and physician assistants only get reimbursed 85% of what a physician would otherwise receive in reimbursement. If the “incident to” requirements are met, even though the service was not provided by a physician, the organization would receive 100% reimbursement. Although this revenue opportunity is huge for many practices, ...

What is incident to billing?

Incident to billing is a method of providing a service in which a physician or non-physician practitioner is not the individual actually providing the professional services which will later be billed to Medicare or Medicaid. The most popular utilization of “incident to” billing relates to the interactions between nurse practitioners or physician assistants and physicians. In this type of arrangement, a physician will initially treat the patient and then follow up visits will be provided by a nurse practitioner or physician assistant.

Why is it so hard to maintain compliance when billing incident to?

Finally, incident to billing can be problematic in settings in which a patient may come to the office for reasons outside of the initial diagnosis.

How much did the physician settle for in the incident to allegations?

The physician and the practice resolved the allegations by settling for nearly $100,000. “through this data mining, government investigators were able to determine that the Center had billed for services allegedly rendered by Dr.

Does Medicare pay for incident to billing?

The regulations state that Medicare will pay (100% of the physician fee schedule) for services and supplies that meet the following conditions: Services and supplies must be furnished in a noninstitutional setting ...

Can a nurse practitioner bill for incident to?

This means that a nurse practitioner or physician assistant cannot bill “incident to” if the service is not either in the course of the diagnosis that the physician made or if the service is not in the course of treatment by the physician. This requirement creates serious issues for practices and organizations because if a patient visits ...

Did Michael Fox bill his NPI?

Specifically, Dr. Michael Fox was alleged to have billed under his NPI for the services even though the “incident to” requirements had not been met. The government claimed that the physician involvement was minimal in that the “incident to” provisions would not apply. The physician and the practice resolved the allegations by settling for nearly $100,000.

How much did Medicare charge for non-physician providers in 1999?

Since these changes were made in the BBA of 1997, Medicare charges for these nonphysician providers rose from $55 million to $202 million in 1999, according to a June 2001 report by the Office of the Inspector General (OIG).

What are incident to Medicare?

When Medicare was enacted, Congress provided for payment to the physician who directly interacted with the patient but also recognized that physicians received help in their offices. The incident-to rules were established to cover services that are “an integral, although incidental, part of the physician’s personal professional services to the patient.” Because these services are so intertwined with those that physicians provide, a claim for nonphysician providers’ services that are incident to the physician’s service can be submitted as if the physician performed the service. The nonphysician providers are invisible on the claim form, and the claim is paid at 100 percent of the physician fee schedule. Keep in mind that the incident-to rules apply only to Medicare reimbursement. For information on how other payers reimburse for the services of nonphysician providers, see “ Other payers ” below.

What is the role of non-physician providers in physician practices?

As part of the Balanced Budget Act (BBA) of 1997, Congress recognized the role that certain nonphysician providers (nurse practitioners, physician assistants and clinical nurse specialists) play in physician practices by liberalizing the conditions under which they can bill using their own provider numbers.

Does Medicare require a physician to see established patients?

Although some local carriers also require the physician to see established patients each time they present with a new symptom, national Medicare policy does not require this. Nonphysician providers may bill incident-to for their services during and after that visit.

What is the CPT code for stress test?

The appropriate level of supervision is determined by the CPT code for the test. For example, an electrocardiogram (CPT code 93000) requires only general supervision, but a stress test (93015) requires direct supervision and a transesophageal echocardiogram (93312) requires personal supervision.

Does Medicare cover non-physician services?

Medicare provides reimbursement for nonphysician provider services that are “incident to” a physician’s care. Failing to bill for incident-to services can cost a practice thousands of dollars. When billing incident-to, a practice can be reimbursed at 100 percent of the physician fee schedule for non-physician provider services.

Does Medicare recognize midlevel providers?

This includes a variety of midlevel providers, nurses and medical assistants, among others. One way Medicare recognizes these individuals for payment purposes is by reimbursing physicians for services provided “incident to” a physician’s care. As the use of nonphysician providers in family practices has evolved, ...

What is incident to billing?

With incident to billing, the physician bills and collects 100% of Medicare’s allowable reimbursement. This type of billing is used when an NPP sees a patient in which the physician has performed the initial service and has initiated a Plan of Care or treatment plan. There are specific rules for this type of billing, the physician must be on site, in the suite, not just in the building, and provides direct supervision (the rules for home visits varies).

What is a DNP in medical?

NPs are nurses who hold a Master’s Degree or Doctor of Nursing Practice (DNP).

Do mid level providers need to have their own NPI?

It is very important that each of your mid-level providers receives his/her own National Provider Identifier (NPI) and be credentialed with each payer to bill under his/her PIN number, if possible, based on payer rules and regulations. However, many payers will not credential NPPs.

Can a payer credential a NPP?

However, many payers will not credential NPPs. Having the NPP credentialed allows practices to bill insurance companies directly when the “supervising physician” is either not on site or has not provided any care or input into patient’s plan of care.

Can a physician and NPP be in the same group?

The physician and the qualified NPP must be in the same group practice or be employed by the same employer.”. Billing for shared/split services allows the practice to bill under the qualified physician versus the NPP at their lower reimbursement rate. As long as the criteria are met, billing for shared/split services allows for ...

Post COVID-19 Reimbursement Parity for Nurse Practitioners

Alycia Bischof, MSN, APRN, PNP-BC Sherry A. Greenberg, PhD, RN, GNP-BC, FGSA, FAANP, FAAN

Abstract

Reimbursement parity of nurse practitioners (NPs) and physicians is appropriate now more than ever. Studies have demonstrated that NPs provide the same quality of care as physicians, yet they do not receive the same reimbursement.

MedPAC and Reimbursement Policy

Current Medicare reimbursement for NPs comes from the Balanced Budget Act (1997) (See Table 2 ). Nurse lobbying groups compromised on the NP reimbursement rate of 85% of the physician fee because the location restriction for NP care was removed. As the number of NPs continued to rise, removing the location barrier was a great feat ( Apold, 2011 ).

Considerations for Post COVID-19 Policy Solutions

The Rural Health Clinic Services Act ( 1977) enabled NPs to bill Medicare directly, without a supervising physician. From this point, NPs could provide more independent care. Often that care is still provided to patients in underserved communities, where physician shortages have left the population without accessible care.

Action Steps to Move Forward

Call for 100% of Physician Payment Rate Medicare should increase the reimbursement rate of NPs to 100% of the physician payment rate. Medicare should increase the reimbursement rate of NPs to 100% of the physician payment rate.

Summary

Evolution of practice since 2002 provides considerable rationale, discussed in this article, that lends support to the question by MedPAC, “do physicians and NPPs produce the same product?” ( MedPAC, 2002 ). Now is the time for NPs to receive full reimbursement from Medicare.

What is incident to services?

Note: “Incident to” services are also relevant to services supervised by certain non-physician practitioners such as physician assistants, nurse practitioners, clinical nurse specialists, nurse midwives, or clinical psychologists. These services are subject to the same requirements as physician-supervised services. Remember that “incident services” supervised by non-physician practitioners are reimbursed at 85 percent of the physician fee schedule. For clarity’s sake, this article will refer to “physician” services as inclusive of non-physician practitioners.

Can an incident to billing be confusing?

Incident-to billing can be confusing. Unfortunately, many NPs find their employers want to bill under incident-to, yet there is often a mis-understanding of this issue, as we’ve t alked about before. The problem is it can potentially result in fraud charges if the rules are not followed.

The Confusion

Anecdotally, it appears that confusion and misunderstanding as to when it is permissible to bill ARNP or PA services as if the physician personally provided the service stems from the disconnect between the NPP’s scope of practice, which may require just general supervision, and that of “incident to” billing, which requires direct supervision (ie, a billing physician in the office suite).

Final Thoughts

It must be noted that this article only discusses the CMS requirements for “incident to” billing. As more NPPs begin working in rheumatology practices, it is imperative that other payer policies be checked. Some insurers, such as Florida Blue, do not allow any NPP “incident to” billing.

What is incident to services?

Incident-to services must be an integral – although incidental – part of the physician's personal professional services and be part of the patient's normal course of treatment. The services must be of the type commonly furnished in a physician's office or clinic (as opposed to physicians working in a hospital setting).

Does Medicare require incident to billing?

But to qualify for incident-to designation, the services must meet certain requirements. These specific requirements only apply to Medicare, but some private insurance plans allow incident-to billing using similar rules.

Can NPPs bill for counseling?

NPPs can bill for counseling or coordination of care in their own names at 85 percent of the MPFS. Also, while qualified NPPs may perform diagnostic tests and be supervised by physicians while doing so, diagnostic tests may never be billed incident-to.

Can incident to billing increase Medicare?

Under incident-to and other similar Medicare billing concepts, physicians can increase their bottom line while reducing the number of patients they must personally see. However, physicians must adhere to the rules governing incident-to billing, and must navigate the process of hiring and maintaining Medicare enrollment information for NPPs.

Does Medicare cover E/M?

Conclusion. Medicare also permits physicians who provide evaluation and management (E/M) services to hospital inpatients, to hospital outpatients, or in the emergency department to bill for “shared visits.”.

Can a physician have a plenary license?

Typically, state laws grant physicians a plenary license while restricting other providers' scope of practice to include only some of the activities physicians may perform. While anything an NPP may do typically falls within a physician's scope of practice, the opposite is not true.

Does Medicare require a physician to be on site?

Medicare rules determine the degree of physician supervision required: General supervision – The physician need not be on-site, Direct supervision – The physician must be in the office suite but not necessarily in the same room, Personal supervision – The physician must be in the same room with the patient and NPP.

Abstract

Increasing patient demand following health care reform has led to concerns about provider shortages, particularly in primary care and for Medicaid patients. Nurse practitioners (NPs) represent a potential solution to meeting demand.

Introduction

Under the Patient Protection and Affordable Care Act, over 22 million Americans have gained health care coverage through private health insurance and Medicaid ( Medicaid. gov, 2015; U.S. Department of Health and Human Services, 2015 ).

Conceptual Basis for the Study

This study was based on the conceptual understanding that, examined together, both NP SOP and NP Medicaid reimbursement policies have the potential to influence NP participation in primary care and practice Medicaid acceptance.

Method

The primary data for this cross-sectional study were extracted from the 2012 SK&A physician and NP/PA files. SK&A is a market research firm that maintains and frequently updates information on ambulatory practices in all 50 states and D.C. ( SK&A, 2016 ). Data are collected during the previous calendar year.

Results

Just over 6% (6.3%) of practices were located in “fully enabled” states (i.e., full SOP and 100% NP Medicaid reimbursement), and 35.5% of practices were in states that had neither “fully enabled” policy in place ( Appendix Table A3 ). The remaining 58.3% of practices were in states categorized as either full SOP or 100% Medicaid reimbursement.

Discussion

Our findings indicate that NP participation in primary care is greatest in states that allow for both full SOP and 100% NP Medicaid reimbursement.

Acknowledgments

The authors thank the Leonard Davis Institute of Health Economics workforce working group in facilitating access to the data, as well as Dr. Doug Sloane and Dr. Daniel E. Polsky for their comments and suggestions during manuscript preparation.

What percentage of the physician fee is paid under NPP?

Many health plan contracts agree to pay for services billed under NPP provider numbers at 85 percent of the physician fee schedule. If you employ an NPP or anticipate hiring one, you might be able to negotiate a better reimbursement rate when you evaluate your next contract.

What is incident to billing?

In addition to understanding the requirements for incident-to billing, you should familiarize yourself with “shared visits,” a term created by the Centers for Medicare & Medicaid Services that applies only to Medicare patients. In general, incident-to services are for office-based services, and shared visits are for hospital services. Specifically, shared visits are evaluation and management (E/M) services provided to inpatients in a hospital or outpatients in the emergency department. These services are literally “shared” between you and an NPP. If both you and the NPP have a face-to-face encounter with the patient, the service can be billed under your provider number and is reimbursed at 100 percent of the physician fee schedule.

What is a NPP in family medicine?

From physician assistants to clinical nurse specialists, nonphysician practitioners (NPPs) offer a variety of services in family medicine practices. Some NPPs see acute visits and walk-in patients; some care for patients who are chronically ill and who need longer visits and care coordination; some care for patients in the hospital;

What is an NPP?

In some practices, an NPP's role may include all these activities. In addition to physician assistants and clinical nurse specialists, NPPs can include any of the following: nurse practitioners, certified nurse midwives, biofeedback technicians, respiratory therapists, physical and occupational therapists, psychologists, social workers, ...

What is incident to services?

In general, incident-to services are for office-based services, and shared visits are for hospital services. Specifically, shared visits are evaluation and management (E/M) services provided to inpatients in a hospital or outpatients in the emergency department. These services are literally “shared” between you and an NPP.

Do health plans get paid for NPPs?

Get paid for the work you do. Health plans are free to set their own policies for credentialing NPPs and providing reimbursement for their services. Some plans credential NPPs and allow their services to be billed under the NPPs' provider numbers.

Do NPPs know their state?

For example, each state has regulations regarding the scope of practice and level of supervision required for each type of practitioner. Most NPPs know the laws in their own state, but you should also familiarize yourself with these laws to know which services are permitted.

Incident to Fraud and Abuse

  • The Department of Justice allegedthat Jacksonville Center for Reproductive Medicine misused incident to billing for services of a nurse practitioner and physician assistant. Specifically, Dr. Michael Fox was alleged to have billed under his NPI for the services even though the “incident to” requirements had not been met. The government claimed that...
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What Are The Requirements of Incident to Billing?

  • As stated earlier, incident to billing can take the form of many different types of arrangements. However, incident to billing is primarily used by physicians with nurse practitioners and physician assistants. As noted above, the compliance risks are significant and can result in severe penalties if the requirements for incident to billing have not bee met. There are various sources to assist u…
See more on thehealthcarelawyer.com

Can A Nurse Practitioner Bill Incident to?

  • The Medicare regulations allow a nurse practitioner to have a service or supply billed incident to the nurse practitioner’s NPI. Specifically, 42 CFR 410.75 states that services and supplies are covered only if they: 1. Would be covered if furnished by a physician or as incident to the professional services of a physician; 2. Are of the type that are commonly furnished in a physicia…
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Learning Points

  • Although “incident to” billing can provide additional revenue to a practice, it does present substantial risks. Maintaining compliance when billing incident to can be extremely tough especially because at times it may be impossible to have a physician on site. Finally, incident to billing can be problematic in settings in which a patient may come to the office for reasons outsi…
See more on thehealthcarelawyer.com

How to Bill For Nurse Practitioners and Physician Assistants

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You would be hard pressed to find a medical practice that does not use Physician Assistants (PAs) and Nurse Practitioners (NPs), also referred to as physician extenders or non-physician practitioners (NPPs). Understanding how to properly bill and code for servicesprovided by NPPs is imperative to running a cost-effective a…
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Direct Pay

  • Direct pay is when the NPP holds their own Provider Identification Number (PIN). This reimburses the NPP (or practice) at 85% of the billable physician rate. It is very important that each of your mid-level providers receives his/her own National Provider Identifier (NPI) and be credentialed with each payer to bill under his/her PIN number, if possible, based on payer rules and regulation…
See more on capturebilling.com

“Incident To”

  • “Incident to” billing is a way of billing outpatient services rendered in a physician’s office located in a separate office or in an institution, or in a patient’s home provided by a non-physician practitioner (NPP). With incident to billing, the physician bills and collects 100% of Medicare’s allowable reimbursement. This type of billing is used when an NPP sees a patient in which the p…
See more on capturebilling.com

Split/Shared Expenses

  • Split/shared expenses: “A split/shared E/M visit is defined by Medicare Part B payment policy as a medically necessary encounter with a patient where the physician and a qualified NPP each personally perform a substantive portion of an E/M visit face-to-face with the same patient on the same date of service. A substantive portion of an E/M visit involves all or some portion of the his…
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Conclusion

  • With shifts in healthcare spending, patient care, and reimbursement, and physician shortages, the need for Nurse Practitioners and Physician Assistants is greater than ever. A Proper understanding of the billing and reimbursement guidelines for individual payers is necessary. Charting and documentation requirements must be met. Does your medical practice use NPs or …
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Abstract

  • Citation: Bischof, A., Greenberg, S.A., (May 31, 2021) "Post COVID-19 Reimbursement Parity for Nurse Practitioners" OJIN: The Online Journal of Issues in NursingVol. 26, No. 2, Manuscript 3. DOI: 10.3912/OJIN.Vol26No02Man03 https://doi.org/10.3912/OJIN.Vol26No02Man03 Key Words:nurse practitioner, advanced practice provider, nursing reimbursement, M...
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Review of The Issues

  • “Incident to” Billing NPs have been providing care for Medicare patients since its inception in1965.NPs have been providing care for Medicare patients since its inception in1965. However, reimbursement for their services has been a journey. Initially, care delivered by NPs was billed under the physician’s name as “incident to” payment. Under “incident to” payment, a non-physicia…
See more on ojin.nursingworld.org

MedPAC and Reimbursement Policy

  • Current Medicare reimbursement for NPs comes from the Balanced Budget Act (1997) (See Table 2). Nurse lobbying groups compromised on the NP reimbursement rate of 85% of the physician fee because the location restriction for NP care was removed. As the number of NPs continued to rise, removing the location barrier was a great feat (Apold, 2011). The MedPAC was also establi…
See more on ojin.nursingworld.org

Considerations For Post Covid-19 Policy Solutions

  • The Rural Health Clinic Services Act (1977) enabled NPs to bill Medicare directly, without a supervising physician. From this point, NPs could provide more independent care. Often that care is still provided to patients in underserved communities, where physician shortages have left the population without accessible care. Nurse-managed health centers and retail clinics that are ru…
See more on ojin.nursingworld.org

Action Steps to Move Forward

  • Call for 100% of Physician Payment Rate Medicare should increase the reimbursement rate of NPs to 100% of the physician payment rate. Medicare should increase the reimbursement rate of NPs to 100% of the physician payment rate. With MedPAC as the organization tasked with advising Congress about best practices for Medicare, action steps to increase reimbursement n…
See more on ojin.nursingworld.org

Summary

  • Evolution of practice since 2002 provides considerable rationale, discussed in this article, that lends support to the question by MedPAC, “do physicians and NPPs produce the same product?” (MedPAC, 2002). Now is the time for NPs to receive full reimbursement from Medicare. The 85% rule was instituted at a time when the work environment looked very different. With an increase i…
See more on ojin.nursingworld.org

Authors

  • Alycia Bischof, MSN, APRN, PNP-BC Email: [email protected] Alycia Bischof is a lecturer at the University of Pennsylvania School of Nursing. She specializes in teaching graduate nursing students about reimbursement and coding in the primary care setting. She is a PNCB board certified, practicing pediatric nurse practitioner. She received a BSN and MSN from the Un…
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References

  • American Association of Nurse Practitioners (AANP). (2013). Nurse practitioner cost effectiveness. AANP Positions and Papers. Retrieved from: https://www.aanp.org/advocacy/advocacy-resource/position-statements/position-statements American Association of Nurse Practitioners (AANP). (2018, March 19). Number of nurse practit…
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