* When may we use the nurse practitioner's UPIN?
* May I withhold access to a patient's medical record because of a past due account?
* Bulletin: OIG targets contractual joint ventures

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Compliance Hot Topics: Billing and Coding, EMTALA, Stark, HIPAA

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Welcome to Compliance Monitor Q&A!

Our mission is to answer your difficult compliance questions-and your simple ones, too. To submit a question, send it to Compliance Monitor Q & A editor Laura Motta at lmotta@hcpro.com. We hope you enjoy this service and we welcome your feedback.

This week's questions

• When may we use the nurse practitioner's UPIN?
• May I withhold access to a patient's medical record because of a past due account?

• Bulletin: OIG targets contractual joint ventures

• Tell us about your chargemaster-and win $50!

Q: If we receive an order for outpatient services, such as labs or x-rays, and then a nurse practitioner or physician assistant signs it, may we bill Medicare using the nurse practitioner's or physician assistant's Unique Provider Identification Number (UPIN)?

A: Based on Medicare regulations, you may either use the physician assistant's or nurse practitioner's UPIN on the CMS-1500 form. Or, you may continue to use the provider number and UPIN of the supervising physician.

This rule was established on January 1, 1998. In sections 4511 and 4512 of the Balanced Budget Act of 1997, lawmakers removed the restriction on the areas and settings Medicare could pay nurse practitioners, physician assistants, and clinical nurse specialists.

Determining which provider number and UPIN to use depends on whether the supervising physician is "on-site" during the services. If your organizationuses the physician's provider and UPIN number, but the services were actually performed by a physician assistant, for example, then you must meet the "incident to" guideline. The guidelines requires the supervising physician to be "on-site" and readily available to the non-physician practitioners during these services.

If the supervising physician is not on site, but reachable by telephone-this is considered general supervision. In this case, you should bill under the provider and UPIN numbers for the nurse practitioner or physician assistant. But make sure they actually performed the service.

As always, proper documentation is paramount to remain in compliance with Medicare regulations. Check with your local carrier as to whether there is a modifier you may use with non-physician practitioner services. As of April 1, 1999, Medicare regulations no longer required modifiers for most services done by nurse practitioners or physician assistants. However, an assistant at surgery still requires a modifier. It is always best to check with your local carrier.

This question was answered by Rick Oliver, JD, CHCO, CPC, MT (ASCP), director of compliance at AmeriPath, Inc.

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Get internal investigations advice from experts

Join HCPro for the 90-minute live audioconference, "Internal Investigations: Know the Risks, Reap the Benefits" and gain tools and strategies to conduct efficient, effective, and beneficial internal investigations and self-audits.

This program will be presented on Thursday, July 24th, 2003, from 1:00-2:30pm (Eastern). To register or learn more, click here, or call our Customer Service Team at 800/650-6787. Be sure to mention Source Code EZ1285A.

Go to "Bulletin: OIG targets contractual joint ventures " for the rest of this article. The cost is $10. Subscribers to the online version of Strategies for Health Care Compliance have free access to this article. Subscribers to the print edition can find it in their July issues.

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You can read this article-and much more-in the July issue of Strategies for Health Care Compliance. Your cost: Four stories for only $30! You'll learn strategies for measuring privacy program effectiveness, plus you'll receive a handout to give to physicians about anti-kickback issues. Choose between a PDF or HTML version for just $30. Online subscribers have free access to this issue. Print newsletter subscribers can find it in their mailboxes.

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Hotly debated and long awaited

The final EMTALA rule is due out within weeks. It's going to have significant implications for hospitals. In short, EMTALA governs the way hospitals have to manage patients coming into the emergency department, and how and when those patients can be transferred. Join us for a live 90-minute audioconference, "EMTALA Final Rule: New Strategies for Compliance" on July 14 beginning at 1 p.m. Eastern. Our speakers will dedicate half the program time to answering your questions.

For information or to register, CLICK HERE, or call our customer service department at 800-650-6787. Be sure to mention Source Code EZ1401B.

A: To read the answer to this question, click here.

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