Loading ...
Sorry, an error occurred while loading the content.

RE: [CRN-L] Question on incident- to billing

Expand Messages
  • Meernik, Shirlene
    Thanks so much for the response Quin and others who did respond. A follow-up question I have after reading the MLN SEO441 is that under the subheading of your
    Message 1 of 19 , Jun 7, 2011
    View Source
    • 0 Attachment
      Thanks so much for the response Quin and others who did respond.

      A follow-up question I have after reading the MLN SEO441 is that under the subheading of "your office" the statement "must be provided by a caregiver whom you directly supervise AND who represents a direct financial expense to you such as... I would appreciate clarification of that statement because to me that sounds like independent physicians rather than a physician who is part of a facility based outpatient setting/office. So if the physician is employed by our organization and is located in a facility based clinic and the NPPs are also employees of our hospital, not the physician, does incident to not apply in this situation?

      ________________________________
      From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of Quinten Buechner
      Sent: Sunday, May 29, 2011 6:21 PM
      To: CRN-L@yahoogroups.com
      Subject: RE: [CRN-L] Question on incident- to billing



      Shirlene: The directive from Medicare is found in IOM 100-02 chapter 15
      section 60. The doc must see first and establish the plan of care that the
      NPP must follow. The Doc must be immediately available in the suite and see
      the patient frequently enough to remain in charge of the TX (generally every
      3rd visit). If there is a change needed in care or tx the Doc must make it.
      He does not have to see the patient but must document the needed change.
      Alternatively take the 155 DISCOUNT IN ALLOWABLE AND BILL UNDER THE NPP.

      Quinten A. Buechner, M.S., M.Div.,
      ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

      President and CEO

      ProActive Consultants, LLC

      1659 3rd Ave, Cumberland, WI 54829

      E-mail: QuinB@...<mailto:QuinB%40centurytel.net>

      Phone: 715.822.8284

      Cell: 715.307.4448

      Fax: 715.822.8299

      From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of
      Meernik, Shirlene
      Sent: Thursday, May 26, 2011 11:33 AM
      To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
      Subject: [CRN-L] Question on incident- to billing

      I am not terribly familiar with incident to billing. It is not something
      that we have done before so there are lots of questions about it. One big
      question before we even get started is about the issue of the physician
      requirement of seeing the patient prior to incident to. There is
      disagreement as to what that means. Does it mean the physician examines or
      provides an initial service to the patient, determines the tx plan,
      documents the service and then the following visits can be provided incident
      to? Or does it mean the provider merely sees the patient prior to the
      incident to provider seeing the patient and just documents a supervisory
      note? Also to satisfy the supervision requirements is there any
      documentation requirements to be made by the supervising provider? Is the
      supervising provider required to periodically see the patient as well and if
      so how frequently?

      Is any of this specifically written somewhere by Medicare that addresses
      these questions because proof in writing is always required! Is there
      anything else I need to be aware of with incident to billing.

      Thanks.

      Shirlene

      This transmission is for the use of the individual or entity named on this
      e-mail. Unauthorized disclosure or access may be prohibited by Public Law
      99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
      (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
      1030, or other applicable criminal laws, and can result in administrative,
      disciplinary or criminal proceedings. This mail system, including this
      transmittal, may be internally monitored for all lawful purposes, including
      ensuring compliance with applicable privacy and security rules as specified
      by HIPAA, Mental Health Code and internal policies. Transmission of
      unencrypted Protected Health Information is prohibited. If this was sent to
      you in error, please notify the sender by reply e-mail and destroy all
      copies and attachments of the original message.

      This transmission is for the use of the individual or entity named on this
      e-mail. Unauthorized disclosure or access may be prohibited by Public Law
      99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
      (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
      1030, or other applicable criminal laws, and can result in administrative,
      disciplinary or criminal proceedings. This mail system, including this
      transmittal, may be internally monitored for all lawful purposes, including
      ensuring compliance with applicable privacy and security rules as specified
      by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services'
      policies and procedures. Transmission of unencrypted Protected Health
      Information is prohibited.

      ________________________________
      If this was sent to you in error, please notify the sender by reply e-mail
      and destroy all copies and attachments of the original message.

      [Non-text portions of this message have been removed]

      _____

      No virus found in this message.
      Checked by AVG - www.avg.com
      Version: 10.0.1375 / Virus Database: 1509/3667 - Release Date: 05/29/11

      [Non-text portions of this message have been removed]




      This transmission is for the use of the individual or entity named on this e-mail. Unauthorized disclosure or access may be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294 (National Information Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal laws, and can result in administrative, disciplinary or criminal proceedings. This mail system, including this transmittal, may be internally monitored for all lawful purposes, including ensuring compliance with applicable privacy and security rules as specified by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services' policies and procedures. Transmission of unencrypted Protected Health Information is prohibited.

      ________________________________
      If this was sent to you in error, please notify the sender by reply e-mail and destroy all copies and attachments of the original message.


      [Non-text portions of this message have been removed]
    • Stevens, Connie
      The services that would normally be billed incident to under the physicians NPI are billed under the facility NPI. Connie Stevens Compliance and Reimbursement
      Message 2 of 19 , Jun 7, 2011
      View Source
      • 0 Attachment
        The services that would normally be billed incident to under the physicians NPI are billed under the facility NPI.

        Connie Stevens
        Compliance and Reimbursement Manager
        cstevens@...
        509-664-4868 ext 5699

        [cid:image001.png@01CC24F2.8347D430]

        From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of Meernik, Shirlene
        Sent: Tuesday, June 07, 2011 6:50 AM
        To: CRN-L@yahoogroups.com
        Subject: RE: [CRN-L] Question on incident- to billing



        Thanks so much for the response Quin and others who did respond.

        A follow-up question I have after reading the MLN SEO441 is that under the subheading of "your office" the statement "must be provided by a caregiver whom you directly supervise AND who represents a direct financial expense to you such as... I would appreciate clarification of that statement because to me that sounds like independent physicians rather than a physician who is part of a facility based outpatient setting/office. So if the physician is employed by our organization and is located in a facility based clinic and the NPPs are also employees of our hospital, not the physician, does incident to not apply in this situation?

        ________________________________
        From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of Quinten Buechner
        Sent: Sunday, May 29, 2011 6:21 PM
        To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
        Subject: RE: [CRN-L] Question on incident- to billing

        Shirlene: The directive from Medicare is found in IOM 100-02 chapter 15
        section 60. The doc must see first and establish the plan of care that the
        NPP must follow. The Doc must be immediately available in the suite and see
        the patient frequently enough to remain in charge of the TX (generally every
        3rd visit). If there is a change needed in care or tx the Doc must make it.
        He does not have to see the patient but must document the needed change.
        Alternatively take the 155 DISCOUNT IN ALLOWABLE AND BILL UNDER THE NPP.

        Quinten A. Buechner, M.S., M.Div.,
        ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

        President and CEO

        ProActive Consultants, LLC

        1659 3rd Ave, Cumberland, WI 54829

        E-mail: QuinB@...<mailto:QuinB%40centurytel.net><mailto:QuinB%40centurytel.net>

        Phone: 715.822.8284

        Cell: 715.307.4448

        Fax: 715.822.8299

        From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>] On Behalf Of
        Meernik, Shirlene
        Sent: Thursday, May 26, 2011 11:33 AM
        To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>
        Subject: [CRN-L] Question on incident- to billing

        I am not terribly familiar with incident to billing. It is not something
        that we have done before so there are lots of questions about it. One big
        question before we even get started is about the issue of the physician
        requirement of seeing the patient prior to incident to. There is
        disagreement as to what that means. Does it mean the physician examines or
        provides an initial service to the patient, determines the tx plan,
        documents the service and then the following visits can be provided incident
        to? Or does it mean the provider merely sees the patient prior to the
        incident to provider seeing the patient and just documents a supervisory
        note? Also to satisfy the supervision requirements is there any
        documentation requirements to be made by the supervising provider? Is the
        supervising provider required to periodically see the patient as well and if
        so how frequently?

        Is any of this specifically written somewhere by Medicare that addresses
        these questions because proof in writing is always required! Is there
        anything else I need to be aware of with incident to billing.

        Thanks.

        Shirlene

        This transmission is for the use of the individual or entity named on this
        e-mail. Unauthorized disclosure or access may be prohibited by Public Law
        99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
        (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
        1030, or other applicable criminal laws, and can result in administrative,
        disciplinary or criminal proceedings. This mail system, including this
        transmittal, may be internally monitored for all lawful purposes, including
        ensuring compliance with applicable privacy and security rules as specified
        by HIPAA, Mental Health Code and internal policies. Transmission of
        unencrypted Protected Health Information is prohibited. If this was sent to
        you in error, please notify the sender by reply e-mail and destroy all
        copies and attachments of the original message.

        This transmission is for the use of the individual or entity named on this
        e-mail. Unauthorized disclosure or access may be prohibited by Public Law
        99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
        (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
        1030, or other applicable criminal laws, and can result in administrative,
        disciplinary or criminal proceedings. This mail system, including this
        transmittal, may be internally monitored for all lawful purposes, including
        ensuring compliance with applicable privacy and security rules as specified
        by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services'
        policies and procedures. Transmission of unencrypted Protected Health
        Information is prohibited.

        ________________________________
        If this was sent to you in error, please notify the sender by reply e-mail
        and destroy all copies and attachments of the original message.

        [Non-text portions of this message have been removed]

        _____

        No virus found in this message.
        Checked by AVG - www.avg.com
        Version: 10.0.1375 / Virus Database: 1509/3667 - Release Date: 05/29/11

        [Non-text portions of this message have been removed]

        This transmission is for the use of the individual or entity named on this e-mail. Unauthorized disclosure or access may be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294 (National Information Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal laws, and can result in administrative, disciplinary or criminal proceedings. This mail system, including this transmittal, may be internally monitored for all lawful purposes, including ensuring compliance with applicable privacy and security rules as specified by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services' policies and procedures. Transmission of unencrypted Protected Health Information is prohibited.

        ________________________________
        If this was sent to you in error, please notify the sender by reply e-mail and destroy all copies and attachments of the original message.

        [Non-text portions of this message have been removed]


        ________________________________
        This e-mail message, including any attachments, is for the
        sole use of the intended recipient(s) and may contain
        confidential or privileged information. Any unauthorized
        review, use, disclosure or distribution is prohibited. If
        you are not the intended recipient, please contact the
        sender by reply e-mail and destroy the message.


        [Non-text portions of this message have been removed]
      • QuinB@centurytel.net
        Sometimes reading the MLN leaves one more confused than not. Understand Medicare presumes you can go from the simplist scenario to the more complex, so they
        Message 3 of 19 , Jun 7, 2011
        View Source
        • 0 Attachment
          Sometimes reading the MLN leaves one more confused than not.
          Understand Medicare presumes you can go from the simplist scenario to
          the more complex, so they often write policy from the single doc or
          small group practice. Generally, Medicare's take is: if you meet the
          essence of IOM 100-02, 15, 60, you are ok. What they don't say clearly
          is that they accept the State Scope of Practice rules as being basic
          and then you add on the Medicare policy. For "Incident To", that can be
          problematic. For example, Medicare says that any other Doc in the
          practice can substitue for the ordering'supervising doc. And that is
          true if the State allows it. Some States demand only 1 supervising doc
          and no one else. Others say all the docs in the practice can supervise.
          Still others will allow you to name a small group of doc as
          supervisors. Finally, a few say 1 supervisor unless you notify the
          State in advance that some one else will supervise. So you can be
          billing correctly but at the same time putting the licience of the Doc
          and NPP in jeprody.

          Now when discussing clinic services, you start making things
          complex. The issue is who is really paying the NPP and Doc. If the NPP
          and Doc belong to a separate practice and you bill them both on a 1500,
          you use the Part B "Incident To" rules from IOM 100-02, 15, 60. But the
          way you phrased the question can cause a problem. You see both Part A
          and Part B have "Incident to" rules and they are not the same. If the
          NPP salary is part of the hospital cost pool like the Nurses or MAs,
          then you must follow the Part A rules which speak to staffing and
          supervision and get billed on the UB as part of the rate. If both are
          employees of the hospital and are billed as professional services on a
          1500, then you use Part Bs "Incident To" rule (IOM 100-02, 15, 60). The
          same thing is true if both are employees of an independent practice as
          a separate organization

          Quinten A. Buechner, M.S., M.Div.,
          ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

          Assoc. Prof. & Program Chair, Billing and Coding, Herzing Univ.

          President and CEO

          ProActive Consultants, LLC

          1659 3rd Ave, Cumberland, WI 54829

          E-mail: QuinB@...

          Phone: 715.822.8284

          Cell: 715.307.4448

          Fax: 715.822.8299

          Quoting "Stevens, Connie" :

          The services that would normally be billed incident to under the
          physicians NPI are billed under the facility NPI.

          Connie Stevens
          Compliance and Reimbursement Manager
          cstevens@...
          509-664-4868 ext 5699

          [cid:image001.png@01CC24F2.8347D430]

          From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of
          Meernik, Shirlene
          Sent: Tuesday, June 07, 2011 6:50 AM
          To: CRN-L@yahoogroups.com
          Subject: RE: [CRN-L] Question on incident- to billing

          Thanks so much for the response Quin and others who did respond.

          A follow-up question I have after reading the MLN SEO441 is that under
          the subheading of "your office" the statement "must be provided by a
          caregiver whom you directly supervise AND who represents a direct
          financial expense to you such as... I would appreciate clarification of
          that statement because to me that sounds like independent physicians
          rather than a physician who is part of a facility based outpatient
          setting/office. So if the physician is employed by our organization and
          is located in a facility based clinic and the NPPs are also employees
          of our hospital, not the physician, does incident to not apply in this
          situation?

          ________________________________
          From: CRN-L@yahoogroups.com[mailto:CRN-L@yahoogroups.com] On Behalf Of
          Quinten Buechner Sent: Sunday, May 29, 2011 6:21 PM To:
          CRN-L@yahoogroups.com Subject: RE: [CRN-L] Question on incident- to
          billing Shirlene: The directive from Medicare is found in IOM 100-02
          chapter 15 section 60. The doc must see first and establish the plan of
          care that the NPP must follow. The Doc must be immediately available in
          the suite and see the patient frequently enough to remain in charge of
          the TX (generally every 3rd visit). If there is a change needed in care
          or tx the Doc must make it. He does not have to see the patient but
          must document the needed change. Alternatively take the 155 DISCOUNT IN
          ALLOWABLE AND BILL UNDER THE NPP. Quinten A. Buechner, M.S., M.Div.,
          ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS) President and
          CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland, WI 54829
          E-mail: QuinB@... Phone: 715.822.8284 Cell: 715.307.4448
          Fax: 715.822.8299 From: CRN-L@yahoogroups.com
          [mailto:CRN-L@yahoogroups.com] On Behalf Of Meernik, Shirlene Sent:
          Thursday, May 26, 2011 11:33 AM To: CRN-L@yahoogroups.com Subject:
          [CRN-L] Question on incident- to billing I am not terribly familiar
          with incident to billing. It is not something that we have done before
          so there are lots of questions about it. One big question before we
          even get started is about the issue of the physician requirement of
          seeing the patient prior to incident to. There is disagreement as to
          what that means. Does it mean the physician examines or provides an
          initial service to the patient, determines the tx plan, documents the
          service and then the following visits can be provided incident to? Or
          does it mean the provider merely sees the patient prior to the incident
          to provider seeing the patient and just documents a supervisory note?
          Also to satisfy the supervision requirements is there any documentation
          requirements to be made by the supervising provider? Is the supervising
          provider required to periodically see the patient as well and if so how
          frequently? Is any of this specifically written somewhere by Medicare
          that addresses these questions because proof in writing is always
          required! Is there anything else I need to be aware of with incident to
          billing. Thanks. Shirlene This transmission is for the use of the
          individual or entity named on this e-mail. Unauthorized disclosure or
          access may be prohibited by Public Law 99-474 (The Computer Fraud and
          Abuse Act of 1986), Public Law 104-294 (National Information
          Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other
          applicable criminal laws, and can result in administrative,
          disciplinary or criminal proceedings. This mail system, including this
          transmittal, may be internally monitored for all lawful purposes,
          including ensuring compliance with applicable privacy and security
          rules as specified by HIPAA, Mental Health Code and internal policies.
          Transmission of unencrypted Protected Health Information is prohibited.
          If this was sent to you in error, please notify the sender by reply
          e-mail and destroy all copies and attachments of the original message.
          This transmission is for the use of the individual or entity named on
          this e-mail. Unauthorized disclosure or access may be prohibited by
          Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public
          Law 104-294 (National Information Infrastructure Protection Act of
          1996), 18 U.S.C. 1030, or other applicable criminal laws, and can
          result in administrative, disciplinary or criminal proceedings. This
          mail system, including this transmittal, may be internally monitored
          for all lawful purposes, including ensuring compliance with applicable
          privacy and security rules as specified by HIPAA, Mental Health Code
          and Pine Rest Christian Mental Health Services' policies and
          procedures. Transmission of unencrypted Protected Health Information is
          prohibited. ________________________________ If this was sent to you in
          error, please notify the sender by reply e-mail and destroy all copies
          and attachments of the original message. [Non-text portions of this
          message have been removed] _____ No virus found in this message.
          Checked by AVG - www.avg.com Version: 10.0.1375 / Virus Database:
          1509/3667 - Release Date: 05/29/11 [Non-text portions of this message
          have been removed] This transmission is for the use of the individual
          or entity named on this e-mail. Unauthorized disclosure or access may
          be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
          1986), Public Law 104-294 (National Information Infrastructure
          Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
          laws, and can result in administrative, disciplinary or criminal
          proceedings. This mail system, including this transmittal, may be
          internally monitored for all lawful purposes, including ensuring
          compliance with applicable privacy and security rules as specified by
          HIPAA, Mental Health Code and Pine Rest Christian Mental Health
          Services' policies and procedures. Transmission of unencrypted
          Protected Health Information is prohibited.
          ________________________________ If this was sent to you in error,
          please notify the sender by reply e-mail and destroy all copies and
          attachments of the original message. [Non-text portions of this message
          have been removed] ________________________________ This e-mail
          message, including any attachments, is for the sole use of the intended
          recipient(s) and may contain confidential or privileged information.
          Any unauthorized review, use, disclosure or distribution is prohibited.
          If you are not the intended recipient, please contact the sender by
          reply e-mail and destroy the message. [Non-text portions of this
          message have been removed]



          [Non-text portions of this message have been removed]
        • Meernik, Shirlene
          Wow! They sure don t make things simple do they? Both the physician and the NPP are employed by our hospital so we would then use the Part B incident to rules
          Message 4 of 19 , Jun 7, 2011
          View Source
          • 0 Attachment
            Wow! They sure don't make things simple do they? Both the physician and the NPP are employed by our hospital so we would then use the Part B incident to rules is that correct? I had no idea there was different rules for Part A and B! I think I am now more confused than ever.

            ________________________________
            From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of QuinB@...
            Sent: Tuesday, June 07, 2011 2:34 PM
            To: CRN-L@yahoogroups.com
            Subject: RE: [CRN-L] Question on incident- to billing




            Sometimes reading the MLN leaves one more confused than not.
            Understand Medicare presumes you can go from the simplist scenario to
            the more complex, so they often write policy from the single doc or
            small group practice. Generally, Medicare's take is: if you meet the
            essence of IOM 100-02, 15, 60, you are ok. What they don't say clearly
            is that they accept the State Scope of Practice rules as being basic
            and then you add on the Medicare policy. For "Incident To", that can be
            problematic. For example, Medicare says that any other Doc in the
            practice can substitue for the ordering'supervising doc. And that is
            true if the State allows it. Some States demand only 1 supervising doc
            and no one else. Others say all the docs in the practice can supervise.
            Still others will allow you to name a small group of doc as
            supervisors. Finally, a few say 1 supervisor unless you notify the
            State in advance that some one else will supervise. So you can be
            billing correctly but at the same time putting the licience of the Doc
            and NPP in jeprody.

            Now when discussing clinic services, you start making things
            complex. The issue is who is really paying the NPP and Doc. If the NPP
            and Doc belong to a separate practice and you bill them both on a 1500,
            you use the Part B "Incident To" rules from IOM 100-02, 15, 60. But the
            way you phrased the question can cause a problem. You see both Part A
            and Part B have "Incident to" rules and they are not the same. If the
            NPP salary is part of the hospital cost pool like the Nurses or MAs,
            then you must follow the Part A rules which speak to staffing and
            supervision and get billed on the UB as part of the rate. If both are
            employees of the hospital and are billed as professional services on a
            1500, then you use Part Bs "Incident To" rule (IOM 100-02, 15, 60). The
            same thing is true if both are employees of an independent practice as
            a separate organization

            Quinten A. Buechner, M.S., M.Div.,
            ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

            Assoc. Prof. & Program Chair, Billing and Coding, Herzing Univ.

            President and CEO

            ProActive Consultants, LLC

            1659 3rd Ave, Cumberland, WI 54829

            E-mail: QuinB@...<mailto:QuinB%40centurytel.net>

            Phone: 715.822.8284

            Cell: 715.307.4448

            Fax: 715.822.8299

            Quoting "Stevens, Connie" :

            The services that would normally be billed incident to under the
            physicians NPI are billed under the facility NPI.

            Connie Stevens
            Compliance and Reimbursement Manager
            cstevens@...<mailto:cstevens%40wvmedical.com>
            509-664-4868 ext 5699

            [cid:image001.png@01CC24F2.8347D430<mailto:image001.png%4001CC24F2.8347D430>]

            From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of
            Meernik, Shirlene
            Sent: Tuesday, June 07, 2011 6:50 AM
            To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
            Subject: RE: [CRN-L] Question on incident- to billing

            Thanks so much for the response Quin and others who did respond.

            A follow-up question I have after reading the MLN SEO441 is that under
            the subheading of "your office" the statement "must be provided by a
            caregiver whom you directly supervise AND who represents a direct
            financial expense to you such as... I would appreciate clarification of
            that statement because to me that sounds like independent physicians
            rather than a physician who is part of a facility based outpatient
            setting/office. So if the physician is employed by our organization and
            is located in a facility based clinic and the NPPs are also employees
            of our hospital, not the physician, does incident to not apply in this
            situation?

            ________________________________
            From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>[mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of
            Quinten Buechner Sent: Sunday, May 29, 2011 6:21 PM To:
            CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> Subject: RE: [CRN-L] Question on incident- to
            billing Shirlene: The directive from Medicare is found in IOM 100-02
            chapter 15 section 60. The doc must see first and establish the plan of
            care that the NPP must follow. The Doc must be immediately available in
            the suite and see the patient frequently enough to remain in charge of
            the TX (generally every 3rd visit). If there is a change needed in care
            or tx the Doc must make it. He does not have to see the patient but
            must document the needed change. Alternatively take the 155 DISCOUNT IN
            ALLOWABLE AND BILL UNDER THE NPP. Quinten A. Buechner, M.S., M.Div.,
            ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS) President and
            CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland, WI 54829
            E-mail: QuinB@...<mailto:QuinB%40centurytel.net> Phone: 715.822.8284 Cell: 715.307.4448
            Fax: 715.822.8299 From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
            [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of Meernik, Shirlene Sent:
            Thursday, May 26, 2011 11:33 AM To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> Subject:
            [CRN-L] Question on incident- to billing I am not terribly familiar
            with incident to billing. It is not something that we have done before
            so there are lots of questions about it. One big question before we
            even get started is about the issue of the physician requirement of
            seeing the patient prior to incident to. There is disagreement as to
            what that means. Does it mean the physician examines or provides an
            initial service to the patient, determines the tx plan, documents the
            service and then the following visits can be provided incident to? Or
            does it mean the provider merely sees the patient prior to the incident
            to provider seeing the patient and just documents a supervisory note?
            Also to satisfy the supervision requirements is there any documentation
            requirements to be made by the supervising provider? Is the supervising
            provider required to periodically see the patient as well and if so how
            frequently? Is any of this specifically written somewhere by Medicare
            that addresses these questions because proof in writing is always
            required! Is there anything else I need to be aware of with incident to
            billing. Thanks. Shirlene This transmission is for the use of the
            individual or entity named on this e-mail. Unauthorized disclosure or
            access may be prohibited by Public Law 99-474 (The Computer Fraud and
            Abuse Act of 1986), Public Law 104-294 (National Information
            Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other
            applicable criminal laws, and can result in administrative,
            disciplinary or criminal proceedings. This mail system, including this
            transmittal, may be internally monitored for all lawful purposes,
            including ensuring compliance with applicable privacy and security
            rules as specified by HIPAA, Mental Health Code and internal policies.
            Transmission of unencrypted Protected Health Information is prohibited.
            If this was sent to you in error, please notify the sender by reply
            e-mail and destroy all copies and attachments of the original message.
            This transmission is for the use of the individual or entity named on
            this e-mail. Unauthorized disclosure or access may be prohibited by
            Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public
            Law 104-294 (National Information Infrastructure Protection Act of
            1996), 18 U.S.C. 1030, or other applicable criminal laws, and can
            result in administrative, disciplinary or criminal proceedings. This
            mail system, including this transmittal, may be internally monitored
            for all lawful purposes, including ensuring compliance with applicable
            privacy and security rules as specified by HIPAA, Mental Health Code
            and Pine Rest Christian Mental Health Services' policies and
            procedures. Transmission of unencrypted Protected Health Information is
            prohibited. ________________________________ If this was sent to you in
            error, please notify the sender by reply e-mail and destroy all copies
            and attachments of the original message. [Non-text portions of this
            message have been removed] _____ No virus found in this message.
            Checked by AVG - www.avg.com Version: 10.0.1375 / Virus Database:
            1509/3667 - Release Date: 05/29/11 [Non-text portions of this message
            have been removed] This transmission is for the use of the individual
            or entity named on this e-mail. Unauthorized disclosure or access may
            be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
            1986), Public Law 104-294 (National Information Infrastructure
            Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
            laws, and can result in administrative, disciplinary or criminal
            proceedings. This mail system, including this transmittal, may be
            internally monitored for all lawful purposes, including ensuring
            compliance with applicable privacy and security rules as specified by
            HIPAA, Mental Health Code and Pine Rest Christian Mental Health
            Services' policies and procedures. Transmission of unencrypted
            Protected Health Information is prohibited.
            ________________________________ If this was sent to you in error,
            please notify the sender by reply e-mail and destroy all copies and
            attachments of the original message. [Non-text portions of this message
            have been removed] ________________________________ This e-mail
            message, including any attachments, is for the sole use of the intended
            recipient(s) and may contain confidential or privileged information.
            Any unauthorized review, use, disclosure or distribution is prohibited.
            If you are not the intended recipient, please contact the sender by
            reply e-mail and destroy the message. [Non-text portions of this
            message have been removed]

            [Non-text portions of this message have been removed]




            This transmission is for the use of the individual or entity named on this e-mail. Unauthorized disclosure or access may be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294 (National Information Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal laws, and can result in administrative, disciplinary or criminal proceedings. This mail system, including this transmittal, may be internally monitored for all lawful purposes, including ensuring compliance with applicable privacy and security rules as specified by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services' policies and procedures. Transmission of unencrypted Protected Health Information is prohibited.

            ________________________________
            If this was sent to you in error, please notify the sender by reply e-mail and destroy all copies and attachments of the original message.


            [Non-text portions of this message have been removed]
          • Stevens, Connie
            Quinn you are so right. I didn t read her entire question and thought she was referring to the support services not the NPP - which we call midlevel - hope I
            Message 5 of 19 , Jun 7, 2011
            View Source
            • 0 Attachment
              Quinn you are so right. I didn't read her entire question and thought she was referring to the support services not the NPP - which we call midlevel - hope I didn't cause more confusion.

              Connie Stevens
              Compliance and Reimbursement Manager
              cstevens@...
              509-664-4868 ext 5699

              [cid:image001.png@01CC250C.463F2380]

              From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of QuinB@...
              Sent: Tuesday, June 07, 2011 11:34 AM
              To: CRN-L@yahoogroups.com
              Subject: RE: [CRN-L] Question on incident- to billing




              Sometimes reading the MLN leaves one more confused than not.
              Understand Medicare presumes you can go from the simplist scenario to
              the more complex, so they often write policy from the single doc or
              small group practice. Generally, Medicare's take is: if you meet the
              essence of IOM 100-02, 15, 60, you are ok. What they don't say clearly
              is that they accept the State Scope of Practice rules as being basic
              and then you add on the Medicare policy. For "Incident To", that can be
              problematic. For example, Medicare says that any other Doc in the
              practice can substitue for the ordering'supervising doc. And that is
              true if the State allows it. Some States demand only 1 supervising doc
              and no one else. Others say all the docs in the practice can supervise.
              Still others will allow you to name a small group of doc as
              supervisors. Finally, a few say 1 supervisor unless you notify the
              State in advance that some one else will supervise. So you can be
              billing correctly but at the same time putting the licience of the Doc
              and NPP in jeprody.

              Now when discussing clinic services, you start making things
              complex. The issue is who is really paying the NPP and Doc. If the NPP
              and Doc belong to a separate practice and you bill them both on a 1500,
              you use the Part B "Incident To" rules from IOM 100-02, 15, 60. But the
              way you phrased the question can cause a problem. You see both Part A
              and Part B have "Incident to" rules and they are not the same. If the
              NPP salary is part of the hospital cost pool like the Nurses or MAs,
              then you must follow the Part A rules which speak to staffing and
              supervision and get billed on the UB as part of the rate. If both are
              employees of the hospital and are billed as professional services on a
              1500, then you use Part Bs "Incident To" rule (IOM 100-02, 15, 60). The
              same thing is true if both are employees of an independent practice as
              a separate organization

              Quinten A. Buechner, M.S., M.Div.,
              ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

              Assoc. Prof. & Program Chair, Billing and Coding, Herzing Univ.

              President and CEO

              ProActive Consultants, LLC

              1659 3rd Ave, Cumberland, WI 54829

              E-mail: QuinB@...<mailto:QuinB%40centurytel.net>

              Phone: 715.822.8284

              Cell: 715.307.4448

              Fax: 715.822.8299

              Quoting "Stevens, Connie" :

              The services that would normally be billed incident to under the
              physicians NPI are billed under the facility NPI.

              Connie Stevens
              Compliance and Reimbursement Manager
              cstevens@...<mailto:cstevens%40wvmedical.com>
              509-664-4868 ext 5699

              [cid:image001.png@01CC24F2.8347D430<mailto:image001.png%4001CC24F2.8347D430>]

              From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of
              Meernik, Shirlene
              Sent: Tuesday, June 07, 2011 6:50 AM
              To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
              Subject: RE: [CRN-L] Question on incident- to billing

              Thanks so much for the response Quin and others who did respond.

              A follow-up question I have after reading the MLN SEO441 is that under
              the subheading of "your office" the statement "must be provided by a
              caregiver whom you directly supervise AND who represents a direct
              financial expense to you such as... I would appreciate clarification of
              that statement because to me that sounds like independent physicians
              rather than a physician who is part of a facility based outpatient
              setting/office. So if the physician is employed by our organization and
              is located in a facility based clinic and the NPPs are also employees
              of our hospital, not the physician, does incident to not apply in this
              situation?

              ________________________________
              From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>[mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of
              Quinten Buechner Sent: Sunday, May 29, 2011 6:21 PM To:
              CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> Subject: RE: [CRN-L] Question on incident- to
              billing Shirlene: The directive from Medicare is found in IOM 100-02
              chapter 15 section 60. The doc must see first and establish the plan of
              care that the NPP must follow. The Doc must be immediately available in
              the suite and see the patient frequently enough to remain in charge of
              the TX (generally every 3rd visit). If there is a change needed in care
              or tx the Doc must make it. He does not have to see the patient but
              must document the needed change. Alternatively take the 155 DISCOUNT IN
              ALLOWABLE AND BILL UNDER THE NPP. Quinten A. Buechner, M.S., M.Div.,
              ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS) President and
              CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland, WI 54829
              E-mail: QuinB@...<mailto:QuinB%40centurytel.net> Phone: 715.822.8284 Cell: 715.307.4448
              Fax: 715.822.8299 From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
              [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of Meernik, Shirlene Sent:
              Thursday, May 26, 2011 11:33 AM To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> Subject:
              [CRN-L] Question on incident- to billing I am not terribly familiar
              with incident to billing. It is not something that we have done before
              so there are lots of questions about it. One big question before we
              even get started is about the issue of the physician requirement of
              seeing the patient prior to incident to. There is disagreement as to
              what that means. Does it mean the physician examines or provides an
              initial service to the patient, determines the tx plan, documents the
              service and then the following visits can be provided incident to? Or
              does it mean the provider merely sees the patient prior to the incident
              to provider seeing the patient and just documents a supervisory note?
              Also to satisfy the supervision requirements is there any documentation
              requirements to be made by the supervising provider? Is the supervising
              provider required to periodically see the patient as well and if so how
              frequently? Is any of this specifically written somewhere by Medicare
              that addresses these questions because proof in writing is always
              required! Is there anything else I need to be aware of with incident to
              billing. Thanks. Shirlene This transmission is for the use of the
              individual or entity named on this e-mail. Unauthorized disclosure or
              access may be prohibited by Public Law 99-474 (The Computer Fraud and
              Abuse Act of 1986), Public Law 104-294 (National Information
              Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other
              applicable criminal laws, and can result in administrative,
              disciplinary or criminal proceedings. This mail system, including this
              transmittal, may be internally monitored for all lawful purposes,
              including ensuring compliance with applicable privacy and security
              rules as specified by HIPAA, Mental Health Code and internal policies.
              Transmission of unencrypted Protected Health Information is prohibited.
              If this was sent to you in error, please notify the sender by reply
              e-mail and destroy all copies and attachments of the original message.
              This transmission is for the use of the individual or entity named on
              this e-mail. Unauthorized disclosure or access may be prohibited by
              Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public
              Law 104-294 (National Information Infrastructure Protection Act of
              1996), 18 U.S.C. 1030, or other applicable criminal laws, and can
              result in administrative, disciplinary or criminal proceedings. This
              mail system, including this transmittal, may be internally monitored
              for all lawful purposes, including ensuring compliance with applicable
              privacy and security rules as specified by HIPAA, Mental Health Code
              and Pine Rest Christian Mental Health Services' policies and
              procedures. Transmission of unencrypted Protected Health Information is
              prohibited. ________________________________ If this was sent to you in
              error, please notify the sender by reply e-mail and destroy all copies
              and attachments of the original message. [Non-text portions of this
              message have been removed] _____ No virus found in this message.
              Checked by AVG - www.avg.com Version: 10.0.1375 / Virus Database:
              1509/3667 - Release Date: 05/29/11 [Non-text portions of this message
              have been removed] This transmission is for the use of the individual
              or entity named on this e-mail. Unauthorized disclosure or access may
              be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
              1986), Public Law 104-294 (National Information Infrastructure
              Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
              laws, and can result in administrative, disciplinary or criminal
              proceedings. This mail system, including this transmittal, may be
              internally monitored for all lawful purposes, including ensuring
              compliance with applicable privacy and security rules as specified by
              HIPAA, Mental Health Code and Pine Rest Christian Mental Health
              Services' policies and procedures. Transmission of unencrypted
              Protected Health Information is prohibited.
              ________________________________ If this was sent to you in error,
              please notify the sender by reply e-mail and destroy all copies and
              attachments of the original message. [Non-text portions of this message
              have been removed] ________________________________ This e-mail
              message, including any attachments, is for the sole use of the intended
              recipient(s) and may contain confidential or privileged information.
              Any unauthorized review, use, disclosure or distribution is prohibited.
              If you are not the intended recipient, please contact the sender by
              reply e-mail and destroy the message. [Non-text portions of this
              message have been removed]

              [Non-text portions of this message have been removed]


              ________________________________
              This e-mail message, including any attachments, is for the
              sole use of the intended recipient(s) and may contain
              confidential or privileged information. Any unauthorized
              review, use, disclosure or distribution is prohibited. If
              you are not the intended recipient, please contact the
              sender by reply e-mail and destroy the message.


              [Non-text portions of this message have been removed]
            • Stevens, Connie
              Shirleen - employment is not the key for the NPP - it is where is the cost being declared? If your hospital is putting the NPP salary on the cost report they
              Message 6 of 19 , Jun 7, 2011
              View Source
              • 0 Attachment
                Shirleen - employment is not the key for the NPP - it is where is the cost being declared? If your hospital is putting the NPP salary on the cost report they cannot bill professional services even as incident to. Their services would be billed as facility charges. If not on the cost report then you can follow the physician incident to rules for NPPs. Check with the hospital CFO/dept to find out how they are reported.

                Connie Stevens
                Compliance and Reimbursement Manager
                cstevens@...
                509-664-4868 ext 5699

                [cid:image001.png@...8F350]

                From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of Meernik, Shirlene
                Sent: Tuesday, June 07, 2011 11:49 AM
                To: CRN-L@yahoogroups.com
                Subject: RE: [CRN-L] Question on incident- to billing



                Wow! They sure don't make things simple do they? Both the physician and the NPP are employed by our hospital so we would then use the Part B incident to rules is that correct? I had no idea there was different rules for Part A and B! I think I am now more confused than ever.

                ________________________________
                From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of QuinB@...<mailto:QuinB%40centurytel.net>
                Sent: Tuesday, June 07, 2011 2:34 PM
                To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
                Subject: RE: [CRN-L] Question on incident- to billing

                Sometimes reading the MLN leaves one more confused than not.
                Understand Medicare presumes you can go from the simplist scenario to
                the more complex, so they often write policy from the single doc or
                small group practice. Generally, Medicare's take is: if you meet the
                essence of IOM 100-02, 15, 60, you are ok. What they don't say clearly
                is that they accept the State Scope of Practice rules as being basic
                and then you add on the Medicare policy. For "Incident To", that can be
                problematic. For example, Medicare says that any other Doc in the
                practice can substitue for the ordering'supervising doc. And that is
                true if the State allows it. Some States demand only 1 supervising doc
                and no one else. Others say all the docs in the practice can supervise.
                Still others will allow you to name a small group of doc as
                supervisors. Finally, a few say 1 supervisor unless you notify the
                State in advance that some one else will supervise. So you can be
                billing correctly but at the same time putting the licience of the Doc
                and NPP in jeprody.

                Now when discussing clinic services, you start making things
                complex. The issue is who is really paying the NPP and Doc. If the NPP
                and Doc belong to a separate practice and you bill them both on a 1500,
                you use the Part B "Incident To" rules from IOM 100-02, 15, 60. But the
                way you phrased the question can cause a problem. You see both Part A
                and Part B have "Incident to" rules and they are not the same. If the
                NPP salary is part of the hospital cost pool like the Nurses or MAs,
                then you must follow the Part A rules which speak to staffing and
                supervision and get billed on the UB as part of the rate. If both are
                employees of the hospital and are billed as professional services on a
                1500, then you use Part Bs "Incident To" rule (IOM 100-02, 15, 60). The
                same thing is true if both are employees of an independent practice as
                a separate organization

                Quinten A. Buechner, M.S., M.Div.,
                ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

                Assoc. Prof. & Program Chair, Billing and Coding, Herzing Univ.

                President and CEO

                ProActive Consultants, LLC

                1659 3rd Ave, Cumberland, WI 54829

                E-mail: QuinB@...<mailto:QuinB%40centurytel.net><mailto:QuinB%40centurytel.net>

                Phone: 715.822.8284

                Cell: 715.307.4448

                Fax: 715.822.8299

                Quoting "Stevens, Connie" :

                The services that would normally be billed incident to under the
                physicians NPI are billed under the facility NPI.

                Connie Stevens
                Compliance and Reimbursement Manager
                cstevens@...<mailto:cstevens%40wvmedical.com><mailto:cstevens%40wvmedical.com>
                509-664-4868 ext 5699

                [cid:image001.png@01CC24F2.8347D430<mailto:image001.png%4001CC24F2.8347D430><mailto:image001.png%4001CC24F2.8347D430>]

                From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>] On Behalf Of
                Meernik, Shirlene
                Sent: Tuesday, June 07, 2011 6:50 AM
                To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>
                Subject: RE: [CRN-L] Question on incident- to billing

                Thanks so much for the response Quin and others who did respond.

                A follow-up question I have after reading the MLN SEO441 is that under
                the subheading of "your office" the statement "must be provided by a
                caregiver whom you directly supervise AND who represents a direct
                financial expense to you such as... I would appreciate clarification of
                that statement because to me that sounds like independent physicians
                rather than a physician who is part of a facility based outpatient
                setting/office. So if the physician is employed by our organization and
                is located in a facility based clinic and the NPPs are also employees
                of our hospital, not the physician, does incident to not apply in this
                situation?

                ________________________________
                From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>[mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>] On Behalf Of
                Quinten Buechner Sent: Sunday, May 29, 2011 6:21 PM To:
                CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com> Subject: RE: [CRN-L] Question on incident- to
                billing Shirlene: The directive from Medicare is found in IOM 100-02
                chapter 15 section 60. The doc must see first and establish the plan of
                care that the NPP must follow. The Doc must be immediately available in
                the suite and see the patient frequently enough to remain in charge of
                the TX (generally every 3rd visit). If there is a change needed in care
                or tx the Doc must make it. He does not have to see the patient but
                must document the needed change. Alternatively take the 155 DISCOUNT IN
                ALLOWABLE AND BILL UNDER THE NPP. Quinten A. Buechner, M.S., M.Div.,
                ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS) President and
                CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland, WI 54829
                E-mail: QuinB@...<mailto:QuinB%40centurytel.net><mailto:QuinB%40centurytel.net> Phone: 715.822.8284 Cell: 715.307.4448
                Fax: 715.822.8299 From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>
                [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com>] On Behalf Of Meernik, Shirlene Sent:
                Thursday, May 26, 2011 11:33 AM To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com><mailto:CRN-L%40yahoogroups.com> Subject:
                [CRN-L] Question on incident- to billing I am not terribly familiar
                with incident to billing. It is not something that we have done before
                so there are lots of questions about it. One big question before we
                even get started is about the issue of the physician requirement of
                seeing the patient prior to incident to. There is disagreement as to
                what that means. Does it mean the physician examines or provides an
                initial service to the patient, determines the tx plan, documents the
                service and then the following visits can be provided incident to? Or
                does it mean the provider merely sees the patient prior to the incident
                to provider seeing the patient and just documents a supervisory note?
                Also to satisfy the supervision requirements is there any documentation
                requirements to be made by the supervising provider? Is the supervising
                provider required to periodically see the patient as well and if so how
                frequently? Is any of this specifically written somewhere by Medicare
                that addresses these questions because proof in writing is always
                required! Is there anything else I need to be aware of with incident to
                billing. Thanks. Shirlene This transmission is for the use of the
                individual or entity named on this e-mail. Unauthorized disclosure or
                access may be prohibited by Public Law 99-474 (The Computer Fraud and
                Abuse Act of 1986), Public Law 104-294 (National Information
                Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other
                applicable criminal laws, and can result in administrative,
                disciplinary or criminal proceedings. This mail system, including this
                transmittal, may be internally monitored for all lawful purposes,
                including ensuring compliance with applicable privacy and security
                rules as specified by HIPAA, Mental Health Code and internal policies.
                Transmission of unencrypted Protected Health Information is prohibited.
                If this was sent to you in error, please notify the sender by reply
                e-mail and destroy all copies and attachments of the original message.
                This transmission is for the use of the individual or entity named on
                this e-mail. Unauthorized disclosure or access may be prohibited by
                Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public
                Law 104-294 (National Information Infrastructure Protection Act of
                1996), 18 U.S.C. 1030, or other applicable criminal laws, and can
                result in administrative, disciplinary or criminal proceedings. This
                mail system, including this transmittal, may be internally monitored
                for all lawful purposes, including ensuring compliance with applicable
                privacy and security rules as specified by HIPAA, Mental Health Code
                and Pine Rest Christian Mental Health Services' policies and
                procedures. Transmission of unencrypted Protected Health Information is
                prohibited. ________________________________ If this was sent to you in
                error, please notify the sender by reply e-mail and destroy all copies
                and attachments of the original message. [Non-text portions of this
                message have been removed] _____ No virus found in this message.
                Checked by AVG - www.avg.com Version: 10.0.1375 / Virus Database:
                1509/3667 - Release Date: 05/29/11 [Non-text portions of this message
                have been removed] This transmission is for the use of the individual
                or entity named on this e-mail. Unauthorized disclosure or access may
                be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                1986), Public Law 104-294 (National Information Infrastructure
                Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                laws, and can result in administrative, disciplinary or criminal
                proceedings. This mail system, including this transmittal, may be
                internally monitored for all lawful purposes, including ensuring
                compliance with applicable privacy and security rules as specified by
                HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                Services' policies and procedures. Transmission of unencrypted
                Protected Health Information is prohibited.
                ________________________________ If this was sent to you in error,
                please notify the sender by reply e-mail and destroy all copies and
                attachments of the original message. [Non-text portions of this message
                have been removed] ________________________________ This e-mail
                message, including any attachments, is for the sole use of the intended
                recipient(s) and may contain confidential or privileged information.
                Any unauthorized review, use, disclosure or distribution is prohibited.
                If you are not the intended recipient, please contact the sender by
                reply e-mail and destroy the message. [Non-text portions of this
                message have been removed]

                [Non-text portions of this message have been removed]

                This transmission is for the use of the individual or entity named on this e-mail. Unauthorized disclosure or access may be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294 (National Information Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal laws, and can result in administrative, disciplinary or criminal proceedings. This mail system, including this transmittal, may be internally monitored for all lawful purposes, including ensuring compliance with applicable privacy and security rules as specified by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services' policies and procedures. Transmission of unencrypted Protected Health Information is prohibited.

                ________________________________
                If this was sent to you in error, please notify the sender by reply e-mail and destroy all copies and attachments of the original message.

                [Non-text portions of this message have been removed]


                ________________________________
                This e-mail message, including any attachments, is for the
                sole use of the intended recipient(s) and may contain
                confidential or privileged information. Any unauthorized
                review, use, disclosure or distribution is prohibited. If
                you are not the intended recipient, please contact the
                sender by reply e-mail and destroy the message.


                [Non-text portions of this message have been removed]
              • QuinB@centurytel.net
                Again, It depends how they are treating the NPP s salary. If they throw it in the cost pools, you can t bill. If they re billing the NPP as Professional
                Message 7 of 19 , Jun 7, 2011
                View Source
                • 0 Attachment
                  Again, It depends how they are treating the NPP's salary. If they
                  throw it in the cost pools, you can't bill. If they're billing the NPP
                  as Professional services then you can. Quin

                  Quoting "Meernik, Shirlene" :

                  Wow! They sure don't make things simple do they? Both the physician
                  and the NPP are employed by our hospital so we would then use the Part
                  B incident to rules is that correct? I had no idea there was different
                  rules for Part A and B! I think I am now more confused than ever.

                  ________________________________
                  From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of
                  QuinB@...
                  Sent: Tuesday, June 07, 2011 2:34 PM
                  To: CRN-L@yahoogroups.com
                  Subject: RE: [CRN-L] Question on incident- to billing

                  Sometimes reading the MLN leaves one more confused than not.
                  Understand Medicare presumes you can go from the simplist scenario to
                  the more complex, so they often write policy from the single doc or
                  small group practice. Generally, Medicare's take is: if you meet the
                  essence of IOM 100-02, 15, 60, you are ok. What they don't say clearly
                  is that they accept the State Scope of Practice rules as being basic
                  and then you add on the Medicare policy. For "Incident To", that can be
                  problematic. For example, Medicare says that any other Doc in the
                  practice can substitue for the ordering'supervising doc. And that is
                  true if the State allows it. Some States demand only 1 supervising doc
                  and no one else. Others say all the docs in the practice can supervise.
                  Still others will allow you to name a small group of doc as
                  supervisors. Finally, a few say 1 supervisor unless you notify the
                  State in advance that some one else will supervise. So you can be
                  billing correctly but at the same time putting the licience of the Doc
                  and NPP in jeprody.

                  Now when discussing clinic services, you start making things
                  complex. The issue is who is really paying the NPP and Doc. If the NPP
                  and Doc belong to a separate practice and you bill them both on a 1500,
                  you use the Part B "Incident To" rules from IOM 100-02, 15, 60. But the
                  way you phrased the question can cause a problem. You see both Part A
                  and Part B have "Incident to" rules and they are not the same. If the
                  NPP salary is part of the hospital cost pool like the Nurses or MAs,
                  then you must follow the Part A rules which speak to staffing and
                  supervision and get billed on the UB as part of the rate. If both are
                  employees of the hospital and are billed as professional services on a
                  1500, then you use Part Bs "Incident To" rule (IOM 100-02, 15, 60). The
                  same thing is true if both are employees of an independent practice as
                  a separate organization

                  Quinten A. Buechner, M.S., M.Div.,
                  ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

                  Assoc. Prof. & Program Chair, Billing and Coding, Herzing Univ.

                  President and CEO

                  ProActive Consultants, LLC

                  1659 3rd Ave, Cumberland, WI 54829

                  E-mail: QuinB@...: 715.822.8284 Cell: 715.307.4448 Fax:
                  715.822.8299 Quoting "Stevens, Connie" : The services that would
                  normally be billed incident to under the physicians NPI are billed
                  under the facility NPI. Connie Stevens Compliance and Reimbursement
                  Manager cstevens@... 509-664-4868 ext 5699
                  [cid:image001.png@01CC24F2.8347D430] From: CRN-L@yahoogroups.com
                  [mailto:CRN-L@yahoogroups.com] On Behalf Of Meernik, Shirlene Sent:
                  Tuesday, June 07, 2011 6:50 AM To: CRN-L@yahoogroups.com Subject: RE:
                  [CRN-L] Question on incident- to billing Thanks so much for the
                  response Quin and others who did respond. A follow-up question I have
                  after reading the MLN SEO441 is that under the subheading of "your
                  office" the statement "must be provided by a caregiver whom you
                  directly supervise AND who represents a direct financial expense to you
                  such as... I would appreciate clarification of that statement because
                  to me that sounds like independent physicians rather than a physician
                  who is part of a facility based outpatient setting/office. So if the
                  physician is employed by our organization and is located in a facility
                  based clinic and the NPPs are also employees of our hospital, not the
                  physician, does incident to not apply in this situation?
                  ________________________________ From:
                  CRN-L@yahoogroups.com[mailto:CRN-L@yahoogroups.com] On Behalf Of
                  Quinten Buechner Sent: Sunday, May 29, 2011 6:21 PM To:
                  CRN-L@yahoogroups.com Subject: RE: [CRN-L] Question on incident- to
                  billing Shirlene: The directive from Medicare is found in IOM 100-02
                  chapter 15 section 60. The doc must see first and establish the plan of
                  care that the NPP must follow. The Doc must be immediately available in
                  the suite and see the patient frequently enough to remain in charge of
                  the TX (generally every 3rd visit). If there is a change needed in care
                  or tx the Doc must make it. He does not have to see the patient but
                  must document the needed change. Alternatively take the 155 DISCOUNT IN
                  ALLOWABLE AND BILL UNDER THE NPP. Quinten A. Buechner, M.S., M.Div.,
                  ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS) President and
                  CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland, WI 54829
                  E-mail: QuinB@... Phone: 715.822.8284 Cell: 715.307.4448
                  Fax: 715.822.8299 From: CRN-L@yahoogroups.com
                  [mailto:CRN-L@yahoogroups.com] On Behalf Of Meernik, Shirlene Sent:
                  Thursday, May 26, 2011 11:33 AM To: CRN-L@yahoogroups.com Subject:
                  [CRN-L] Question on incident- to billing I am not terribly familiar
                  with incident to billing. It is not something that we have done before
                  so there are lots of questions about it. One big question before we
                  even get started is about the issue of the physician requirement of
                  seeing the patient prior to incident to. There is disagreement as to
                  what that means. Does it mean the physician examines or provides an
                  initial service to the patient, determines the tx plan, documents the
                  service and then the following visits can be provided incident to? Or
                  does it mean the provider merely sees the patient prior to the incident
                  to provider seeing the patient and just documents a supervisory note?
                  Also to satisfy the supervision requirements is there any documentation
                  requirements to be made by the supervising provider? Is the supervising
                  provider required to periodically see the patient as well and if so how
                  frequently? Is any of this specifically written somewhere by Medicare
                  that addresses these questions because proof in writing is always
                  required! Is there anything else I need to be aware of with incident to
                  billing. Thanks. Shirlene This transmission is for the use of the
                  individual or entity named on this e-mail. Unauthorized disclosure or
                  access may be prohibited by Public Law 99-474 (The Computer Fraud and
                  Abuse Act of 1986), Public Law 104-294 (National Information
                  Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other
                  applicable criminal laws, and can result in administrative,
                  disciplinary or criminal proceedings. This mail system, including this
                  transmittal, may be internally monitored for all lawful purposes,
                  including ensuring compliance with applicable privacy and security
                  rules as specified by HIPAA, Mental Health Code and internal policies.
                  Transmission of unencrypted Protected Health Information is prohibited.
                  If this was sent to you in error, please notify the sender by reply
                  e-mail and destroy all copies and attachments of the original message.
                  This transmission is for the use of the individual or entity named on
                  this e-mail. Unauthorized disclosure or access may be prohibited by
                  Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public
                  Law 104-294 (National Information Infrastructure Protection Act of
                  1996), 18 U.S.C. 1030, or other applicable criminal laws, and can
                  result in administrative, disciplinary or criminal proceedings. This
                  mail system, including this transmittal, may be internally monitored
                  for all lawful purposes, including ensuring compliance with applicable
                  privacy and security rules as specified by HIPAA, Mental Health Code
                  and Pine Rest Christian Mental Health Services' policies and
                  procedures. Transmission of unencrypted Protected Health Information is
                  prohibited. ________________________________ If this was sent to you in
                  error, please notify the sender by reply e-mail and destroy all copies
                  and attachments of the original message. [Non-text portions of this
                  message have been removed] _____ No virus found in this message.
                  Checked by AVG - www.avg.com Version: 10.0.1375 / Virus Database:
                  1509/3667 - Release Date: 05/29/11 [Non-text portions of this message
                  have been removed] This transmission is for the use of the individual
                  or entity named on this e-mail. Unauthorized disclosure or access may
                  be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                  1986), Public Law 104-294 (National Information Infrastructure
                  Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                  laws, and can result in administrative, disciplinary or criminal
                  proceedings. This mail system, including this transmittal, may be
                  internally monitored for all lawful purposes, including ensuring
                  compliance with applicable privacy and security rules as specified by
                  HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                  Services' policies and procedures. Transmission of unencrypted
                  Protected Health Information is prohibited.
                  ________________________________ If this was sent to you in error,
                  please notify the sender by reply e-mail and destroy all copies and
                  attachments of the original message. [Non-text portions of this message
                  have been removed] ________________________________ This e-mail
                  message, including any attachments, is for the sole use of the intended
                  recipient(s) and may contain confidential or privileged information.
                  Any unauthorized review, use, disclosure or distribution is prohibited.
                  If you are not the intended recipient, please contact the sender by
                  reply e-mail and destroy the message. [Non-text portions of this
                  message have been removed] [Non-text portions of this message have been
                  removed] This transmission is for the use of the individual or entity
                  named on this e-mail. Unauthorized disclosure or access may be
                  prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                  1986), Public Law 104-294 (National Information Infrastructure
                  Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                  laws, and can result in administrative, disciplinary or criminal
                  proceedings. This mail system, including this transmittal, may be
                  internally monitored for all lawful purposes, including ensuring
                  compliance with applicable privacy and security rules as specified by
                  HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                  Services' policies and procedures. Transmission of unencrypted
                  Protected Health Information is prohibited.
                  ________________________________ If this was sent to you in error,
                  please notify the sender by reply e-mail and destroy all copies and
                  attachments of the original message. [Non-text portions of this message
                  have been removed]



                  [Non-text portions of this message have been removed]
                • Meernik, Shirlene
                  Quin, Are you and Connie saying different things? It seems like it to me but maybe its because I m not understanding it. I will ask our CFO but I m quite
                  Message 8 of 19 , Jun 7, 2011
                  View Source
                  • 0 Attachment
                    Quin,

                    Are you and Connie saying different things? It seems like it to me but maybe its because I'm not understanding it. I will ask our CFO but I'm quite certain we are billing their professional fees.

                    ________________________________
                    From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of QuinB@...
                    Sent: Tuesday, June 07, 2011 3:24 PM
                    To: CRN-L@yahoogroups.com
                    Subject: RE: [CRN-L] Question on incident- to billing




                    Again, It depends how they are treating the NPP's salary. If they
                    throw it in the cost pools, you can't bill. If they're billing the NPP
                    as Professional services then you can. Quin

                    Quoting "Meernik, Shirlene" :

                    Wow! They sure don't make things simple do they? Both the physician
                    and the NPP are employed by our hospital so we would then use the Part
                    B incident to rules is that correct? I had no idea there was different
                    rules for Part A and B! I think I am now more confused than ever.

                    ________________________________
                    From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of
                    QuinB@...<mailto:QuinB%40centurytel.net>
                    Sent: Tuesday, June 07, 2011 2:34 PM
                    To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
                    Subject: RE: [CRN-L] Question on incident- to billing

                    Sometimes reading the MLN leaves one more confused than not.
                    Understand Medicare presumes you can go from the simplist scenario to
                    the more complex, so they often write policy from the single doc or
                    small group practice. Generally, Medicare's take is: if you meet the
                    essence of IOM 100-02, 15, 60, you are ok. What they don't say clearly
                    is that they accept the State Scope of Practice rules as being basic
                    and then you add on the Medicare policy. For "Incident To", that can be
                    problematic. For example, Medicare says that any other Doc in the
                    practice can substitue for the ordering'supervising doc. And that is
                    true if the State allows it. Some States demand only 1 supervising doc
                    and no one else. Others say all the docs in the practice can supervise.
                    Still others will allow you to name a small group of doc as
                    supervisors. Finally, a few say 1 supervisor unless you notify the
                    State in advance that some one else will supervise. So you can be
                    billing correctly but at the same time putting the licience of the Doc
                    and NPP in jeprody.

                    Now when discussing clinic services, you start making things
                    complex. The issue is who is really paying the NPP and Doc. If the NPP
                    and Doc belong to a separate practice and you bill them both on a 1500,
                    you use the Part B "Incident To" rules from IOM 100-02, 15, 60. But the
                    way you phrased the question can cause a problem. You see both Part A
                    and Part B have "Incident to" rules and they are not the same. If the
                    NPP salary is part of the hospital cost pool like the Nurses or MAs,
                    then you must follow the Part A rules which speak to staffing and
                    supervision and get billed on the UB as part of the rate. If both are
                    employees of the hospital and are billed as professional services on a
                    1500, then you use Part Bs "Incident To" rule (IOM 100-02, 15, 60). The
                    same thing is true if both are employees of an independent practice as
                    a separate organization

                    Quinten A. Buechner, M.S., M.Div.,
                    ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

                    Assoc. Prof. & Program Chair, Billing and Coding, Herzing Univ.

                    President and CEO

                    ProActive Consultants, LLC

                    1659 3rd Ave, Cumberland, WI 54829

                    E-mail: QuinB@...<mailto:QuinB%40centurytel.netPhone>: 715.822.8284 Cell: 715.307.4448 Fax:
                    715.822.8299 Quoting "Stevens, Connie" : The services that would
                    normally be billed incident to under the physicians NPI are billed
                    under the facility NPI. Connie Stevens Compliance and Reimbursement
                    Manager cstevens@...<mailto:cstevens%40wvmedical.com> 509-664-4868 ext 5699
                    [cid:image001.png@01CC24F2.8347D430<mailto:image001.png%4001CC24F2.8347D430>] From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
                    [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of Meernik, Shirlene Sent:
                    Tuesday, June 07, 2011 6:50 AM To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> Subject: RE:
                    [CRN-L] Question on incident- to billing Thanks so much for the
                    response Quin and others who did respond. A follow-up question I have
                    after reading the MLN SEO441 is that under the subheading of "your
                    office" the statement "must be provided by a caregiver whom you
                    directly supervise AND who represents a direct financial expense to you
                    such as... I would appreciate clarification of that statement because
                    to me that sounds like independent physicians rather than a physician
                    who is part of a facility based outpatient setting/office. So if the
                    physician is employed by our organization and is located in a facility
                    based clinic and the NPPs are also employees of our hospital, not the
                    physician, does incident to not apply in this situation?
                    ________________________________ From:
                    CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>[mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of
                    Quinten Buechner Sent: Sunday, May 29, 2011 6:21 PM To:
                    CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> Subject: RE: [CRN-L] Question on incident- to
                    billing Shirlene: The directive from Medicare is found in IOM 100-02
                    chapter 15 section 60. The doc must see first and establish the plan of
                    care that the NPP must follow. The Doc must be immediately available in
                    the suite and see the patient frequently enough to remain in charge of
                    the TX (generally every 3rd visit). If there is a change needed in care
                    or tx the Doc must make it. He does not have to see the patient but
                    must document the needed change. Alternatively take the 155 DISCOUNT IN
                    ALLOWABLE AND BILL UNDER THE NPP. Quinten A. Buechner, M.S., M.Div.,
                    ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS) President and
                    CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland, WI 54829
                    E-mail: QuinB@...<mailto:QuinB%40centurytel.net> Phone: 715.822.8284 Cell: 715.307.4448
                    Fax: 715.822.8299 From: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>
                    [mailto:CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com>] On Behalf Of Meernik, Shirlene Sent:
                    Thursday, May 26, 2011 11:33 AM To: CRN-L@yahoogroups.com<mailto:CRN-L%40yahoogroups.com> Subject:
                    [CRN-L] Question on incident- to billing I am not terribly familiar
                    with incident to billing. It is not something that we have done before
                    so there are lots of questions about it. One big question before we
                    even get started is about the issue of the physician requirement of
                    seeing the patient prior to incident to. There is disagreement as to
                    what that means. Does it mean the physician examines or provides an
                    initial service to the patient, determines the tx plan, documents the
                    service and then the following visits can be provided incident to? Or
                    does it mean the provider merely sees the patient prior to the incident
                    to provider seeing the patient and just documents a supervisory note?
                    Also to satisfy the supervision requirements is there any documentation
                    requirements to be made by the supervising provider? Is the supervising
                    provider required to periodically see the patient as well and if so how
                    frequently? Is any of this specifically written somewhere by Medicare
                    that addresses these questions because proof in writing is always
                    required! Is there anything else I need to be aware of with incident to
                    billing. Thanks. Shirlene This transmission is for the use of the
                    individual or entity named on this e-mail. Unauthorized disclosure or
                    access may be prohibited by Public Law 99-474 (The Computer Fraud and
                    Abuse Act of 1986), Public Law 104-294 (National Information
                    Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other
                    applicable criminal laws, and can result in administrative,
                    disciplinary or criminal proceedings. This mail system, including this
                    transmittal, may be internally monitored for all lawful purposes,
                    including ensuring compliance with applicable privacy and security
                    rules as specified by HIPAA, Mental Health Code and internal policies.
                    Transmission of unencrypted Protected Health Information is prohibited.
                    If this was sent to you in error, please notify the sender by reply
                    e-mail and destroy all copies and attachments of the original message.
                    This transmission is for the use of the individual or entity named on
                    this e-mail. Unauthorized disclosure or access may be prohibited by
                    Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public
                    Law 104-294 (National Information Infrastructure Protection Act of
                    1996), 18 U.S.C. 1030, or other applicable criminal laws, and can
                    result in administrative, disciplinary or criminal proceedings. This
                    mail system, including this transmittal, may be internally monitored
                    for all lawful purposes, including ensuring compliance with applicable
                    privacy and security rules as specified by HIPAA, Mental Health Code
                    and Pine Rest Christian Mental Health Services' policies and
                    procedures. Transmission of unencrypted Protected Health Information is
                    prohibited. ________________________________ If this was sent to you in
                    error, please notify the sender by reply e-mail and destroy all copies
                    and attachments of the original message. [Non-text portions of this
                    message have been removed] _____ No virus found in this message.
                    Checked by AVG - www.avg.com Version: 10.0.1375 / Virus Database:
                    1509/3667 - Release Date: 05/29/11 [Non-text portions of this message
                    have been removed] This transmission is for the use of the individual
                    or entity named on this e-mail. Unauthorized disclosure or access may
                    be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                    1986), Public Law 104-294 (National Information Infrastructure
                    Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                    laws, and can result in administrative, disciplinary or criminal
                    proceedings. This mail system, including this transmittal, may be
                    internally monitored for all lawful purposes, including ensuring
                    compliance with applicable privacy and security rules as specified by
                    HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                    Services' policies and procedures. Transmission of unencrypted
                    Protected Health Information is prohibited.
                    ________________________________ If this was sent to you in error,
                    please notify the sender by reply e-mail and destroy all copies and
                    attachments of the original message. [Non-text portions of this message
                    have been removed] ________________________________ This e-mail
                    message, including any attachments, is for the sole use of the intended
                    recipient(s) and may contain confidential or privileged information.
                    Any unauthorized review, use, disclosure or distribution is prohibited.
                    If you are not the intended recipient, please contact the sender by
                    reply e-mail and destroy the message. [Non-text portions of this
                    message have been removed] [Non-text portions of this message have been
                    removed] This transmission is for the use of the individual or entity
                    named on this e-mail. Unauthorized disclosure or access may be
                    prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                    1986), Public Law 104-294 (National Information Infrastructure
                    Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                    laws, and can result in administrative, disciplinary or criminal
                    proceedings. This mail system, including this transmittal, may be
                    internally monitored for all lawful purposes, including ensuring
                    compliance with applicable privacy and security rules as specified by
                    HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                    Services' policies and procedures. Transmission of unencrypted
                    Protected Health Information is prohibited.
                    ________________________________ If this was sent to you in error,
                    please notify the sender by reply e-mail and destroy all copies and
                    attachments of the original message. [Non-text portions of this message
                    have been removed]

                    [Non-text portions of this message have been removed]




                    This transmission is for the use of the individual or entity named on this e-mail. Unauthorized disclosure or access may be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294 (National Information Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal laws, and can result in administrative, disciplinary or criminal proceedings. This mail system, including this transmittal, may be internally monitored for all lawful purposes, including ensuring compliance with applicable privacy and security rules as specified by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services' policies and procedures. Transmission of unencrypted Protected Health Information is prohibited.

                    ________________________________
                    If this was sent to you in error, please notify the sender by reply e-mail and destroy all copies and attachments of the original message.


                    [Non-text portions of this message have been removed]
                  • QuinB@centurytel.net
                    I m not sure as I don t remember her email. What I am saying is that in no way shape or form can you Bill :Incident to unless the employer is exactly the
                    Message 9 of 19 , Jun 8, 2011
                    View Source
                    • 0 Attachment
                      I'm not sure as I don't remember her email. What I am saying is that
                      in no way shape or form can you Bill ":Incident to" unless the employer
                      is exactly the same for Doc and NPP. And, that the NPP is only being
                      billed for professional services on the 1500 with no activity directly
                      related to the NPP salary and wages being billed to Part A.

                      Quin

                      Quinten A. Buechner, MS, M.Div.

                      AAPC: CPC, ACMCS: PCS, BMSC: ACS FP/GI/PEDS

                      PHIA: CCP, PAHCS: CMSC

                      Associate Professor and Program Chair,

                      Medical Billing & Insurance Coding

                      Herzing University

                      4006 Washington Road

                      Kenosha, WI 53144

                      Phone: 262.671.0685 xtn 60570

                      E-mail: qbuechner@...

                      Accredited by the Higher Learning Commission and a member of the
                      North Central Association. The Higher Learning Commission can be
                      contacted at www.ncahlc.org or 800.621.7440

                      Quoting "Meernik, Shirlene" :

                      Quin,

                      Are you and Connie saying different things? It seems like it to me but
                      maybe its because I'm not understanding it. I will ask our CFO but I'm
                      quite certain we are billing their professional fees.

                      ________________________________
                      From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of
                      QuinB@...
                      Sent: Tuesday, June 07, 2011 3:24 PM
                      To: CRN-L@yahoogroups.com
                      Subject: RE: [CRN-L] Question on incident- to billing

                      Again, It depends how they are treating the NPP's salary. If they
                      throw it in the cost pools, you can't bill. If they're billing the NPP
                      as Professional services then you can. Quin

                      Quoting "Meernik, Shirlene" :

                      Wow! They sure don't make things simple do they? Both the physician
                      and the NPP are employed by our hospital so we would then use the Part
                      B incident to rules is that correct? I had no idea there was different
                      rules for Part A and B! I think I am now more confused than ever.

                      ________________________________
                      From: CRN-L@yahoogroups.com[mailto:CRN-L@yahoogroups.com] On Behalf Of
                      QuinB@... Sent: Tuesday, June 07, 2011 2:34 PM To:
                      CRN-L@yahoogroups.com Subject: RE: [CRN-L] Question on incident- to
                      billing Sometimes reading the MLN leaves one more confused than not.
                      Understand Medicare presumes you can go from the simplist scenario to
                      the more complex, so they often write policy from the single doc or
                      small group practice. Generally, Medicare's take is: if you meet the
                      essence of IOM 100-02, 15, 60, you are ok. What they don't say clearly
                      is that they accept the State Scope of Practice rules as being basic
                      and then you add on the Medicare policy. For "Incident To", that can be
                      problematic. For example, Medicare says that any other Doc in the
                      practice can substitue for the ordering'supervising doc. And that is
                      true if the State allows it. Some States demand only 1 supervising doc
                      and no one else. Others say all the docs in the practice can supervise.
                      Still others will allow you to name a small group of doc as
                      supervisors. Finally, a few say 1 supervisor unless you notify the
                      State in advance that some one else will supervise. So you can be
                      billing correctly but at the same time putting the licience of the Doc
                      and NPP in jeprody. Now when discussing clinic services, you start
                      making things complex. The issue is who is really paying the NPP and
                      Doc. If the NPP and Doc belong to a separate practice and you bill them
                      both on a 1500, you use the Part B "Incident To" rules from IOM 100-02,
                      15, 60. But the way you phrased the question can cause a problem. You
                      see both Part A and Part B have "Incident to" rules and they are not
                      the same. If the NPP salary is part of the hospital cost pool like the
                      Nurses or MAs, then you must follow the Part A rules which speak to
                      staffing and supervision and get billed on the UB as part of the rate.
                      If both are employees of the hospital and are billed as professional
                      services on a 1500, then you use Part Bs "Incident To" rule (IOM
                      100-02, 15, 60). The same thing is true if both are employees of an
                      independent practice as a separate organization Quinten A. Buechner,
                      M.S., M.Div., ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)
                      Assoc. Prof. & Program Chair, Billing and Coding, Herzing Univ.
                      President and CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland,
                      WI 54829 E-mail: QuinB@...: 715.822.8284 Cell:
                      715.307.4448 Fax: 715.822.8299 Quoting "Stevens, Connie" : The services
                      that would normally be billed incident to under the physicians NPI are
                      billed under the facility NPI. Connie Stevens Compliance and
                      Reimbursement Manager cstevens@... 509-664-4868 ext 5699
                      [cid:image001.png@01CC24F2.8347D430] From: CRN-L@yahoogroups.com
                      [mailto:CRN-L@yahoogroups.com] On Behalf Of Meernik, Shirlene Sent:
                      Tuesday, June 07, 2011 6:50 AM To: CRN-L@yahoogroups.com Subject: RE:
                      [CRN-L] Question on incident- to billing Thanks so much for the
                      response Quin and others who did respond. A follow-up question I have
                      after reading the MLN SEO441 is that under the subheading of "your
                      office" the statement "must be provided by a caregiver whom you
                      directly supervise AND who represents a direct financial expense to you
                      such as... I would appreciate clarification of that statement because
                      to me that sounds like independent physicians rather than a physician
                      who is part of a facility based outpatient setting/office. So if the
                      physician is employed by our organization and is located in a facility
                      based clinic and the NPPs are also employees of our hospital, not the
                      physician, does incident to not apply in this situation?
                      ________________________________ From:
                      CRN-L@yahoogroups.com[mailto:CRN-L@yahoogroups.com] On Behalf Of
                      Quinten Buechner Sent: Sunday, May 29, 2011 6:21 PM To:
                      CRN-L@yahoogroups.com Subject: RE: [CRN-L] Question on incident- to
                      billing Shirlene: The directive from Medicare is found in IOM 100-02
                      chapter 15 section 60. The doc must see first and establish the plan of
                      care that the NPP must follow. The Doc must be immediately available in
                      the suite and see the patient frequently enough to remain in charge of
                      the TX (generally every 3rd visit). If there is a change needed in care
                      or tx the Doc must make it. He does not have to see the patient but
                      must document the needed change. Alternatively take the 155 DISCOUNT IN
                      ALLOWABLE AND BILL UNDER THE NPP. Quinten A. Buechner, M.S., M.Div.,
                      ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS) President and
                      CEO ProActive Consultants, LLC 1659 3rd Ave, Cumberland, WI 54829
                      E-mail: QuinB@... Phone: 715.822.8284 Cell: 715.307.4448
                      Fax: 715.822.8299 From: CRN-L@yahoogroups.com
                      [mailto:CRN-L@yahoogroups.com] On Behalf Of Meernik, Shirlene Sent:
                      Thursday, May 26, 2011 11:33 AM To: CRN-L@yahoogroups.com Subject:
                      [CRN-L] Question on incident- to billing I am not terribly familiar
                      with incident to billing. It is not something that we have done before
                      so there are lots of questions about it. One big question before we
                      even get started is about the issue of the physician requirement of
                      seeing the patient prior to incident to. There is disagreement as to
                      what that means. Does it mean the physician examines or provides an
                      initial service to the patient, determines the tx plan, documents the
                      service and then the following visits can be provided incident to? Or
                      does it mean the provider merely sees the patient prior to the incident
                      to provider seeing the patient and just documents a supervisory note?
                      Also to satisfy the supervision requirements is there any documentation
                      requirements to be made by the supervising provider? Is the supervising
                      provider required to periodically see the patient as well and if so how
                      frequently? Is any of this specifically written somewhere by Medicare
                      that addresses these questions because proof in writing is always
                      required! Is there anything else I need to be aware of with incident to
                      billing. Thanks. Shirlene This transmission is for the use of the
                      individual or entity named on this e-mail. Unauthorized disclosure or
                      access may be prohibited by Public Law 99-474 (The Computer Fraud and
                      Abuse Act of 1986), Public Law 104-294 (National Information
                      Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other
                      applicable criminal laws, and can result in administrative,
                      disciplinary or criminal proceedings. This mail system, including this
                      transmittal, may be internally monitored for all lawful purposes,
                      including ensuring compliance with applicable privacy and security
                      rules as specified by HIPAA, Mental Health Code and internal policies.
                      Transmission of unencrypted Protected Health Information is prohibited.
                      If this was sent to you in error, please notify the sender by reply
                      e-mail and destroy all copies and attachments of the original message.
                      This transmission is for the use of the individual or entity named on
                      this e-mail. Unauthorized disclosure or access may be prohibited by
                      Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public
                      Law 104-294 (National Information Infrastructure Protection Act of
                      1996), 18 U.S.C. 1030, or other applicable criminal laws, and can
                      result in administrative, disciplinary or criminal proceedings. This
                      mail system, including this transmittal, may be internally monitored
                      for all lawful purposes, including ensuring compliance with applicable
                      privacy and security rules as specified by HIPAA, Mental Health Code
                      and Pine Rest Christian Mental Health Services' policies and
                      procedures. Transmission of unencrypted Protected Health Information is
                      prohibited. ________________________________ If this was sent to you in
                      error, please notify the sender by reply e-mail and destroy all copies
                      and attachments of the original message. [Non-text portions of this
                      message have been removed] _____ No virus found in this message.
                      Checked by AVG - www.avg.com Version: 10.0.1375 / Virus Database:
                      1509/3667 - Release Date: 05/29/11 [Non-text portions of this message
                      have been removed] This transmission is for the use of the individual
                      or entity named on this e-mail. Unauthorized disclosure or access may
                      be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                      1986), Public Law 104-294 (National Information Infrastructure
                      Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                      laws, and can result in administrative, disciplinary or criminal
                      proceedings. This mail system, including this transmittal, may be
                      internally monitored for all lawful purposes, including ensuring
                      compliance with applicable privacy and security rules as specified by
                      HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                      Services' policies and procedures. Transmission of unencrypted
                      Protected Health Information is prohibited.
                      ________________________________ If this was sent to you in error,
                      please notify the sender by reply e-mail and destroy all copies and
                      attachments of the original message. [Non-text portions of this message
                      have been removed] ________________________________ This e-mail
                      message, including any attachments, is for the sole use of the intended
                      recipient(s) and may contain confidential or privileged information.
                      Any unauthorized review, use, disclosure or distribution is prohibited.
                      If you are not the intended recipient, please contact the sender by
                      reply e-mail and destroy the message. [Non-text portions of this
                      message have been removed] [Non-text portions of this message have been
                      removed] This transmission is for the use of the individual or entity
                      named on this e-mail. Unauthorized disclosure or access may be
                      prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                      1986), Public Law 104-294 (National Information Infrastructure
                      Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                      laws, and can result in administrative, disciplinary or criminal
                      proceedings. This mail system, including this transmittal, may be
                      internally monitored for all lawful purposes, including ensuring
                      compliance with applicable privacy and security rules as specified by
                      HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                      Services' policies and procedures. Transmission of unencrypted
                      Protected Health Information is prohibited.
                      ________________________________ If this was sent to you in error,
                      please notify the sender by reply e-mail and destroy all copies and
                      attachments of the original message. [Non-text portions of this message
                      have been removed] [Non-text portions of this message have been
                      removed] This transmission is for the use of the individual or entity
                      named on this e-mail. Unauthorized disclosure or access may be
                      prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of
                      1986), Public Law 104-294 (National Information Infrastructure
                      Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal
                      laws, and can result in administrative, disciplinary or criminal
                      proceedings. This mail system, including this transmittal, may be
                      internally monitored for all lawful purposes, including ensuring
                      compliance with applicable privacy and security rules as specified by
                      HIPAA, Mental Health Code and Pine Rest Christian Mental Health
                      Services' policies and procedures. Transmission of unencrypted
                      Protected Health Information is prohibited.
                      ________________________________ If this was sent to you in error,
                      please notify the sender by reply e-mail and destroy all copies and
                      attachments of the original message. [Non-text portions of this message
                      have been removed]



                      [Non-text portions of this message have been removed]
                    Your message has been successfully submitted and would be delivered to recipients shortly.