Shared Billing

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PicPHYASST4Although nurse practitioners(NP) and physician assistants (PA) are a vital part of the patient care team, billing for these services is still problematic and overly complex. The Center for Medicare and Medicaid Services (CMS) has begun to recognize the value of NP/PA care and the extent of their billing challenges. In October 2012, CMS clarified and simplified the requirements for shared services billing. Shared services are billed when an NP/PA and a physician (MD/DO) provide a face-to-face visit with a patient at the same time or on the same day. The change was made in section 15501 of the Medicare Carriers Manual (MCM). Because other insurers frequently follow Medicare rules, this topic is of even greater importance.

In billing for NP, PA and MD/DO services, it is clear that when either professional sees a patient alone, the provider must bill under his own name and provider identification number (PIN). When billing a service for which the physician has established a treatment plan at a previous visit, the billing is also clear. When an NP sees an established patient in such an incident-to situation, the billing is made under the physician’s PIN. These things are not changing. What has been cumbersome, confusing and of negative impact on cash flow is how to bill when both providers see the same patient on the same day for the same problem. CMS has decided against requiring both professionals to file a claim using the code 99499 and attach a letter explaining the shared service. Now, when an NP/PA sees a patient incident to and then calls in the physician to consult on or finish the service, only one provider needs to bill.

In 2013, the CCSC established a task force to address issues of inconsistency in billing and payment by CMS and other payors. This group will analyze the matter and make recommendations to improve payment when shared billing occurs.