Corporate Compliance

Billing for NP or PA services in a hospital

Compliance Monitor, August 18, 2006

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Q:Can a physician bill for nurse practitioner or physician assistant services performed in a hospital on an inpatient? The nurse practitioner or physician's assistant would be an employee of the physician, not the hospital. My recollection from an article I read is that it would not be reimbursable.

A: According to the Federal Register (HHS 410.28) in order to receive Medicare benefits incident to the service of a physician, any services or supplies must be furnished in a noninstitutional setting to noninstitutional patients.

In addition, the services and supplies must the types that are commonly furnished in the office or clinic of a physician.

Based on information I have read, the services in a hospital would not be reimbursable. On the CMS Q&A section, the following question was posted: How should "incident to" service(s) provided in a hospital or a skilled nursing facility (SNF) be billed?

The answer was as follows: For inpatient or outpatient hospital services the "bundling" provision provides that payment for all services is made to the hospital by a Medicare intermediary. Therefore, "incident to" services are not separately billable to the carrier payable under the physician fee schedule.

Thanks to Tracy Livingston, CCS, CCSP, Quality Assurance Director for The Coding Center in Birmingham, AL, for answering today's question.



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