"Incident to" billing: Who can supervise the PA?
Q. As long as my partner is on the premises, do I still have to be in the office when my PA provides incident-to service for one of my patients? If the answer is No, do we bill under my PIN or my partner's?
A. If your partner is present, he counts as the supervising physician, and you may bill your PA's services as incident to-as long as your PA fulfills the other requirements for incident to billing. She must be within her scope of practice and carrying out your established treatment plan. You should bill under your partner's PIN, since he supervised the PA at the time of service.
Q. One of my deaf patients is capable of communicating with me in writing or by typing on a computer. However, she insists on having a sign-language interpreter present when she comes to the office. Does the Americans with Disabilities Act oblige me to provide one?
A. It depends. The ADA requires you to make every effort to ensure that a hearing-disabled patient can understand you and express herself to you as effectively as your other patients. If you can achieve this with a computer, you don't have to provide an interpreter just because the patient prefers one.
However, before you reject her request, you'll need to assess both your patient's communication abilities and your own. How well can she read and write? Will her typing skills affect her communication? Can you explain complicated medical matters in ways she'll understand if you have to do it in writing? For lengthy conversations involving complex matters, a sign-language interpreter simply may be necessary for effective communication.
Be aware that even though the law may not obligate you to provide an interpreter, your patient may still file a complaint or bring a discrimination suit if she's unhappy with the computer solution. So be sure to document that you considered the patient's request, discussed the options with her, and based your decision on your evaluation of her communication needs.
Is your time-off policy unfair?
Q. Recently, on her way home from a skiing weekend, a snowstorm stranded my office manager at the airport and caused her to miss work on Monday. I charged her absence to her vacation time. She says that's unfair and would like me to count it as a sick day, so she'd still have her full number of vacation days. Is there anything wrong with that?
A. It depends on your practice's time-off policy. Your policy manual may require you to charge her absence to vacation time rather than sick time.
However, if your office doesn't have a written policy regarding days off, now would be a good time to establish one-possibly a paid time-off plan where each employee receives a certain amount of days off annually, which she may use at her discretion. It offers more flexibility than traditional plans that allot a specific number of days off for illness, vacation, and personal leave.
In this issue, the answers to our readers' questions were provided by: Judy Capko, Capko & Company, Thousand Oaks, CA; Mark Kropiewnicki, Health Care Consulting Inc., Plymouth Meeting, PA; Alec Ziss, Snug Harbor Consulting, Falmouth, MA.
Do you have a practice management question that may be stumping other doctors, too? Write PMQA Editor, Medical Economics, 5 Paragon Drive, Montvale, NJ 07645-1742, 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.