Question re APP billing

[ghillbert, MSN, NP]

Question re critical care. Since critical care time provided by a PA/NP should not be attested/billed under collaborating physician but under the provider who did the work - what happens with critical care procedures at other places?

I have always billed my own critical care procedures, but now we have APP 'fellows' coming through and I was told to have them sent to the collaborating physician to bill ... is this permitted and it's just critical care time that can't be split/shared? I can't find any CMS guidance on the separately billable procedures done in critical care.

[core0]

1 hour ago, ghillbert said:

Question re critical care. Since critical care time provided by a PA/NP should not be attested/billed under collaborating physician but under the provider who did the work - what happens with critical care procedures at other places?

I have always billed my own critical care procedures, but now we have APP 'fellows' coming through and I was told to have them sent to the collaborating physician to bill ... is this permitted and it's just critical care time that can't be split/shared? I can't find any CMS guidance on the separately billable procedures done in critical care.

It depends on how they are credentialed. Generally in our institution they are licensed NPs and PAs. As such you can't have their procedures billed under the collaborating physician. Either you don't bill for the procedures or you credential them like any other APP and bill for them. We choose not to bill for APP resident procedures or notes. For notes we have them mixed with the resident service so they can bill under shared billing for non critical care E/M by the attending.

[ghillbert, MSN, NP]

Is there any CMS/legal guidance as to the fact that licensed/credentialed NP/PAs cannot bill procedures under the collaborating doc? I think I will need cold facts to address this internally. I hate to just lose the revenue.

[core0]

43 minutes ago, ghillbert said:

Is there any CMS/legal guidance as to the fact that licensed/credentialed NP/PAs cannot bill procedures under the collaborating doc? I think I will need cold facts to address this internally. I hate to just lose the revenue.

So the only way that a physician can bill for a APP service is split/shared billing. Here'e what Medicare has to say about that (via the hospitalist):

"However, shared/split rules restrict the services reported under this billing model, recognizing only evaluation and management (E/M) services (and not procedures) provided in the ED, outpatient hospital clinics, or inpatient hospital (i.e. facility-based services). Shared/split rules do not involve all types of E/M services. For hospitalist programs, critical-care services (99291-99292) are excluded."

This is from Palmetto:

"Question: Can you bill split/shared services for skilled nursing facility (SNF) and nursing facility (NF)?

Answer: No. Split/shared services cannot be performed for nursing facility services, critical care services or procedures."

https://www.palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~JM Part B~Browse by Topic~Frequently Asked Questions~Incident to~AK3F6A4053?open

[ghillbert, MSN, NP]

I knew you'd know, you're the best. Thanks David!