NPP and Physician charging for time

Post here your questions regarding auditing ,coding, documentation, and compliance. Also, join in on the conversation- help your fellow auditors and compliance professionals in the industry.

Moderators: Shannon DeConda, NAMAS Moderator

Post Reply
Posts: 73
Joined: Fri Jun 23, 2017 1:41 pm
Location: Multi-specialty Clinic

Tue Oct 24, 2017 10:55 am

Can the MD count time the advanced practitioner (NPP/ARNP) sees the patient along with his face-to-face time when billing based on time?

He writes "Time is spent in discussion with her reviewing the findings in her case to date. The reason for GYN oncology consultation is explained. First discussion is held by our nurse practitioner (NAMED) and then myself."
"In any moment or decision, the best thing you can do is the right thing." - T.Roosevelt
Shoshana, BA, CPC, CPMA, CPCO, RRT
User avatar
Site Admin
Posts: 431
Joined: Mon Apr 09, 2012 1:54 pm

Wed Nov 08, 2017 8:17 am

If this is office based service this would lead to a split/shared encounter in the office setting. Therefore, first rule- incident-to must be met, and second rule- no new patients allowed.

Now is the loaded $50 million question- if it IS established patient, can you then split/share an established patient with a new problem (which this appears to be) as the physician will then be authenticating the plan of care AND providing substantive portion of the E&M encounter? Well, for every person you will ask every yes comes with a no- oftentimes even to the health law attorney. This goes to risk tolerance. If you are ok understanding the risks associated with billing in this manner and knowing that you may have to appeal and/or fight for reimbursement even in a legal setting, then roll the dice. Best practices say, if the plan of care was not created by the supervising physician, then it should be billed under the NPs NPI.

Your question has been answered by Shannon DeConda, CPC, CPC-I, CEMC, CEMA, CPMA, CRTT
Post Reply