NAMAS Webinar Q&A: Incident-to and Split Shared in 2021, 03/02/2021

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.

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Thu Mar 04, 2021 12:18 pm

Below are the questions received during our recent webinar, Incident-to and Split Shared in 2021, originally presented on March 2, 2021. These questions have been answered by the webinar presenter, Scott Kraft, CPC, CPMA, and the NAMAS team of auditors.

Question 1:
Our practice has Np’s and Pa’s we are a general surgical and vascular specialist some np work with the vascular surgeons and some with the general what happens in hospital is one of our general surgeons or Np’S ask for vascular consult and only one of our Np’s will see patient one of the vascular specialist doesn’t sign off or see patient but our Np’s are not specialty credentialed this is considered loss of charge from what is understood due to Np’s and Pa’s being considered same whether working for general or vascular . Can you please verify.
Answer 1:
I’m not quite sure I understand the question, but will give it a shot. NPs and PAs are both non-physician practitioners so they are typically paid at 85% of the fee schedule amount rather than the full 100% for an MD/DO. The specialty credentialing wouldn’t usually come into play unless there is something payer-specific about that contractually, in which case you should check with the payer as that is not really something I could advise you on.

Question 2:
A registered nurse is performing infusion services at our clinic under the direct supervision of the MD who is treating the patient. Can direct supervision of the infusion procedure be met via telehealth? Can the billing provider be immediately available via audio-video technology?
Answer 2:
During the COVID-19 PHE, there is a waiver in effect from CMS that allows direct supervision to be rendered via telehealth. The supervising physician needs to be immediately available via 2-way real-time audio AND video. They do not need to be connected in real-time for the duration of the supervision, but they do need to be immediately available. This should be explicitly documented. Furthermore, this is a CMS policy. Whether any given commercial payer follows CMS in allowing this waiver or not, is something you will need to check with them.
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