Medicare wellness visit

Specialties NP

Published

Has any NP's ever heard of the Medicare wellness visit being performed by RN's (non-NP / MD)? This surprised me recently when I heard this.

Are these being done in the homes? That surprises me. I do them for a major insurance company but they only hire NPs and MDs. What company is doing these?

How will they get reimbursed since Medicare only pays for NP and MD assessments? Sounds fishy to me.

It was mentioned in passing to me by a private practice. The physician feels it is RN capable work. The particulars related to billing I have no idea about. Obviously the practice would want to get paid by Medicare and would need to comply with the regs, so maybe it's something they feels will change in the future in which more of the duties can be put on RNs shoulders and free up time of providers for other tasks. I didn't want to get into questions with them at the time since they are not my employer. It's kind of interesting to talk about on the forum though.

Specializes in FNP, ONP.

It isn't permissible under medicare regulations. Billing any "G" code for which care was not provided by a MD, DO, NP or PA is fraud.

The medicare guidelines for the Medicare Annual Wellness Visit (AWV) specifically state that any licensed healthcare provider can perform the Medicare Annual Wellness Visit. They even state that a registered dietitian can perform the visit. However, anyone below the level of an NP/PA must perform the visit under the "direct supervision" of the physician..which just means the physician must be available in the suite for immediate consultation. Medicare also states there is no "incident to" requirement for the AWV. Regardless of who actuallly performs the visit, billing should always be done under the physician NPI in order to get full reimbursement; (NPs and PAs only get about 80% reimbursement if billed under their own NPI). The AWV is NOT a physical exam of any type. It is an educational visit for the patient to learn about their own health and set up a preventive screening schedule for the next 5-10 years. There is a long list of the specific requirements, but there is absolutely no reason for a physician to perform the visit themselves. Anything done outside the AWV requirements may be subject to a patient copay and can get the practice into hot water unless they have a signed agreement from the patient stating they are aware of this potential cost ahead of time. The AWV itself is free to the patient with no copay. Most practices do not have any idea what the AWV actually is. They assume it is a full physical exam. It pays to read the fine print.

For more information, you can go to www.informthepatient.com ; they have a lot of really good info on the AWV.

Specializes in Emergency, Family Practice, Occ. Health.

One must never bill under anyone else. An NP has their own NPI number and MUST, per Medicare guidelines bill under that. Doing anything else is representing that the service was provided by another person when in fact it wasn't. That by definition is clearly fraud. Be very careful.

Specializes in FNP, ONP.

MWV for ALL Medicare Advantage plans and some commercial part B plans (for the initial MW visit during the first year of medicare participation) absolutely REQUIRE a CPE. Traditional medicare plans (i.e. plain every day old medicare) do not.

In short, it is really easy to make a mistake here, and since they pay a high reimbursement rate, I suspect MWV billings are scrutinized carefully. I wouldn't ask an RN do them simply because if you accidentally have the RN perform a few Med Adv visits for example, you are going to be screwed in an audit. As in, wearing an orange jumpsuit for 3-9 years type screwed.

Page 2.

Who is Eligible to Provide the AWV with PPPS?

*

A physician who is a doctor of medicine

or osteopathy (as defined in section

1861®(1) of the Social Secu

rity Act (the Act); or,

*

A physician assistant, nurse practitioner, or

clinical nurse specialist (as defined

in section 1861(aa)(5

) of the Act); or,

*

A medical professional (including a healt

h educator, registered dietitian, or

nutrition professional or other licensed prac

titioner) or a team of such medical

professionals, working under the direct supervision (as defined in CFR

410.32(b)(3)(ii)) of a physician as defined in

the first bullet point of this section.

Are RNs included in this provision? Thank you.

Link: http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/mm7079.pdf

From my involvement on multiple conference calls with CMS regarding the AWV: an RN, LVN or LPN may perform the full AWV under the "direct supervision" of a physician without the patient seeing the physician. CMS recognizes that the AWV does not require the physicians expertise for it's performance, but the physician must supervise the AWV. An NP or PA can perform the AWV without the "direct supervision" requirement. CMS specifically advised that NP's and PA's can bill under the physician's NPI for this procedure without using the 'incident to' qualifier that is typically required for an NP or PA to bill under the physician's NPI. CMS fully expects that the G0438 and G0439 codes will be performed by non-physicians and billed under the physician's NPI for full reimbursement.

With regard to the statement above that CMS prohibits anyone with their own NPI from billing under the physicians NPI, I direct you to the following: The Incident to” Provision of Medicare

Wow, thank you everyone for the detailed information and accompanying references! It appears that there may be some gray area / leeway here for AWV courtesy of CMS. I also didn't realize the regs would be different based on traditional Medicare vs. Medicare advantage. Thanks again!

I am an LPN who got fired from a job that I had for three weeks. They hired me because a doctor needed a nurse to do MWV's and he moved to a new office on his own. He told me to hurry over the questions and get them done. In addition I was to perform sticks and run a lab. In that first week I had two patients who could not perform the clock test. One of them was a patient confined to a wheelchair with COPD on o2. The other was on morphine sulfate and a patient who had just finished his first round of chemo. That day we got behind and the doctor got angry did not even let me finish the MWV'sThey overbooked patients for MWV,s and regular office visits. The day after I was fired for not being able to to perform the duties of the job they had a patient scheduled on my lab schedule and a patient on the doctors schedule at the same time. Two different people at the same time.I was the only nurse. The office manager was doing partial vitals to rush and did even know the difference between resp and pulse. I had a school desk for a lab chair and was using a pillow to prop arms on. Large persons could not fit in the school desk. I think they were expecting me to do the welcome to medicare visits which I thought had to be done by a mid level provider. Now I have been fired as a nurse.

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