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Incident-To Billing – WPS J5 Part B eNews:

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Incident-To Services – Supervising Provider Billing Instructions

In the office, among other criteria, incident-to services must be rendered by a qualified provider who is directly supervised. To meet supervision requirements for incident-to, the billing provider does not have to be physically present in the treatment room while the service is being provided, but must be present in the immediate office suite, for the entire duration of the service, to render assistance if needed.

If the billing physician is a solo practitioner, he/she must directly supervise the care. In a group practice, there may be situations when the provider responsible for the treatment plan is not the provider physically present in the office suite when the patient is seen in follow up. Thus, the supervising provider can be different than the ordering provider.

At this time, the supervising physician qualifier for Item 17 of the CMS-1500 (02-12) is not required for incident-to services. In the case of a service provided incident-to, when the person who ordered the service is not supervising, enter the National Provider Identifier (NPI) of the “supervising provider” in the lower unshaded portion of Item 24J. Read more at the following link:

http://www.wpsmedicare.com/j5macpartb/resources/provider_types/incident-services-supervising-provider-billing-instructions.shtml

PQRS and RHC

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Many Rural Health Clinics were surprised by the PQRS Penalty Letters which were received in late 2014 have generated significant confusion.  We, as Rural Health Clinics, were under the impression that RHCs are exempt from PQRS and the associated penalties.

This IS indeed, the case.  Rural Health Clinics are exempt from PQRS penalties.  The problem is a technical one.  The PQRS penalty is based on fee-for-service, CMS-1500 claim submissions.  These claims are paid based on individual, Medicare Part B provider numbers associated with Medicare Part B, non-RHC, group numbers.

CMS does not have a way to associate these non-Rural Health Clinic provider numbers with Medicare Part A, RHC PTAN numbers.

Keep in mind:  the penalty is NOT assessed against Rural Health Clinic Part A payments.  The penalty is only levied on non-RHC services such as hospital, lab, and x-ray.  Your own exposure to these non-Rural Health Clinic penalties should be limited.

Unfortunately, ANY 1500 non-RHC billing will have the penalty applied if no 2013 quality data was submitted and no qualifying hardship was documented.  CMS recently issued a PQRS FAQ statement to this affect.  The penalties being currently applied are based on data submitted (or not) from 2013.  In order to avoid the penalty for 2016, please refer to the following link:

http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014PQRS__Avoiding2016PQRS-PaymentAdjustment_F03-27-2014.pdf

For the time being, these penalties will continue to be assessed on your non-Rural Health Clinic provider numbers.

 

Please call with any questions.

 

Charles James

President and CEO

North American Healthcare Management

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