Health Information Management

Q/A: Physician supervision requirements for outpatient facility

APCs Weekly Monitor, May 29, 2009

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Q: The nurse practitioner (NP) and physician assistant (PA) staff the off-campus clinic with no physician present once weekly. They perform a revisit (CPT code 99212) and bill under their own numbers on the professional side (reimbursed at 85%). May they also bill the visit on the facility side?
 
A: No. CMS’ latest interpretation of the direct supervision requirement for hospital outpatient (facility services) in provider-based clinics requires that a physician be present on the premises and available to assist during the provision of the services. An NP or PA does not meet the regulatory definition of a physician. Even if the professional service meets all requirements, the facility service here does not meet the requirements for a covered outpatient hospital service. Therefore, you may not bill Medicare for the facility service.



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