Selecting level of care; NP supervision; Stark violation
Selecting the right level of care
When reporting an established patient visit, with a detailed history, comprehensive exam, but low medical decision- making, is it correct to code a level three?
Yes. Because even though you have two of the three components required for a higher coding level-a detailed history and comprehensive exam-you'd still have to bill only a level three as long as the problem was minor and required only low-complexity medical decision-making. The coding level must be appropriate for the presenting problem.
What about supervising an NP via cell phone?
Two weeks ago I treated a patient for a rash caused by an insect bite. When he returned for a follow-up appointment, he saw my NP because I had been called out of the office. I was accessible by cell phone, though. Can I bill the visit "incident to"?
Not according to Medicare rules, which require you to be somewhere in the office. In some states, however, being reachable by phone satisfies the requirements for supervision, so if you're dealing with a carrier other than Medicare, you may be able to bill "incident to" under your own number. Check with the carrier.
Can your employee see patients offsite?
I've hired a physical therapist to work part time in my office. He also has his own practice at another location. Some patients have asked if they could have their physical therapy at his office because they find his office hours at our practice inconvenient. Would it violate any laws if we send them there? He would be seeing them as our employee and we would continue to bill their insurance carriers.
Yes, the arrangement you describe would violate Stark laws if the patient were covered by Medicare or Medicaid. It might also violate state self-referral regulations. Under Stark, the physical therapist, as your employee, can see your patients only in the building where you practice or at a "centralized" place used by your group and not shared with anyone else.
In this issue, the answers to our readers' questions were provided by:Ginny Martin, CHBC, Healthcare Consulting Associates of NW Ohio, Waterville, OH; William H. Maruca, Esq., http://www.foxrothschild.com Pittsburgh; Alec Ziss, Snug Harbor Consulting, Falmouth, MA.Do you have a practice management question that may be stumping other doctors, too? Write PMQA Editor, MedicalEconomics, 123 Tice Blvd., Suite 300, Woodcliff Lake, NJ 07677-7664, or send an e-mail to firstname.lastname@example.org
(please include your regular postal address). Sorry, but we're not able to answer readers individually.