The purpose of this policy is to provide guidance for physicians reporting services on behalf of their employed Advanced Practice Health Care Providers, to ensure submitted claims identify that the services were provided in collaboration with a physician and to address services reported by Advanced Practice Health Care Providers. This policy impacts all providers identified as an Advanced Practice Health Care Provider: Physician Assistants (PA), Nurse Practitioners (NP) or Clinical Nurse Specialists (CNS).
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Q: What happens when a patient sees an Advanced Practice Health Care Provider and a physician at the same encounter?
A: When an E/M service is a shared/split encounter between a physician and an Advanced Practice Health Care Provider, the service is considered to have been performed “incident-to” if the requirements for “incident-to” are met and the patient is an established patient. If “incident-to” requirements are not met for a shared/split E/M service, those services should be reported under the Advanced Practice Health Care Provider’s NPI number.
Q: Does the physician actually have to see the patient or actively participate in each service in order for “incidentto” services to apply?
A: No, services provided by Advanced Practice Health Care Providers, who are employed by a physician, may be covered as “incident-to” the physician’s service if the physician provides direct on-site supervision/direction, when the service is provided, even when the patient does not see the physician.