Yes NP’s can bill under a Physician with Physician Provider identification number whenever NP’s are acting under Physicians supervision, And whenever NP’s acting as an individual practitioner, NP’s can bill with Identification number assigned to NP’s.
‘’Incident-to billing’’ is a way of billing outpatient services (rendered in a physician’s office located in a separate office or in an institution, or in a patient’s home) provided by a non-physician practitioner (NPP) such as a nurse practitioner (NP), physician assistant (PA), clinical nurse specialist, certified nurse midwife, clinical psychologist, clinical social worker, physical therapist, or occupational therapist.
NPPs have their own benefit category and may provide services without direct physician supervision. They can bill directly for services and incident-to a physician’s services, if they are licensed by their state to assist perform the services.
Billing under a physician’s PIN
According to the Center for Medicare and Medicaid Services (CMS) National Coverage Provision for incident-to services, when NPPs provide services that are incident-to a physician or other practitioner’s service, they may bill under the physician’s PIN when the service or supply is:
• An integral, although incidental, part of the physician’s professional service;
• Commonly rendered without charge or included in the physician’s bill;
• Of the type that is commonly furnished in physician offices or clinics;
• Furnished by the physician or auxiliary personnel under the physician’s direct supervision.
Medicare defines these services as those performed by a NPP or auxiliary staff member who is acting under the supervision of a physician and who is employed by or contracted with the physician or the legal entity that employs or contracts with the physician.
There must have been a direct, professional service furnished by the physician to initiate the course of treatment of which the service being performed by the non-physician is an incidental part.
This means that the physician must see the patient first, in order to initiate the plan of care for that patient, and the NPP follows that plan of care during subsequent visits.
It also means that if a patient mentions a new problem during a follow-up visit for a problem with an established plan of care, the visit cannot be billed incident-to. For example:
Dr. A is treating a patient for diabetes. The patient’s evaluation and management (E/M) encounter in the office is with a PA of the same group for an upper respiratory infection. Can the PA bill the service incident-to Dr. A and bill under Dr. A’s PIN?
In this situation, the upper-respiratory infection is not part of the treatment for diabetes and, therefore, is not an “integral, although incidental” part of Dr. A’s “professional service.” The PA should not bill incident- to under Dr. A’s provider number, but should bill the appropriate level of new or established E/M service provided under his or her own provider number. The physician must have performed the initial service for the diagnosis or condition, and must remain actively involved in the course of treatment.
Finally, the physician must perform subsequent services that reflect his or her continued active management of the patient’s care.