Q. Can my practice provide anticoagulation monitoring for a Medicare patient in our office as “incident to” a physician’s services? On the other hand, if we refer the patient to an anticoagulation monitoring clinic, can we still bill this service as “incident to”?
A. If you provide anticoagulation monitoring in your office, you can bill Medicare for the service as “incident to” IF it is part of the patient’s normal course of treatment during which a physician or nonphysician practitioner (NPP) in your practice:
- Personally performed an initial service,
- Remains actively involved in the course of treatment, and
- Provides direct supervision. The supervisor doesn’t have to be physically present in the patient’s treatment room while a qualified caregiver actually performs the service but must be in the office suite and available to help, if necessary. In addition, for the service to qualify as “incident to,” the caregiver must be someone who represents a direct expense to the practice, i.e., an employee (can be a leased employee) or an independent contractor.
In the second scenario — if you refer the patient to an outside clinic — your practice cannot bill for the monitoring service as “incident to” because the caregiver performing the service is not under direct supervision of a physician or NPP in your practice.
Note: Remember that Medicare reimburses “incident to” services that NPPs supervise at the rate paid the supervisor, not at the physician fee schedule rate.
For more information, see the Centers for Medicare & Medicaid Services’ Medlearn Matters No. SE 0441 (PDF) and these guidelines from Novitas Solutions.
Updated Aug. 19, 2013
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