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Recent changes mandated by Congress and CMS that boost the status of physician assistants (PA) — or physician associates, as some groups prefer — is another sign that the providers formerly known as mid-levels and extenders are increasingly important to U.S. health care. For medical groups, they may cost more to employ in the years to come.
Question: A new patient came in and saw our physician assistant (PA) for some lacerations. She did not see a doctor. A week later the patient returned for follow up with an M.D. For purposes of billing the E/M, is the doctor visit a new patient visit or an established patient billing?
Some non-physician practitioners (NPPs) and the practices that increasingly rely on them are set to get a break from CMS in 2020, should significant scope-of-practice updates in the proposed 2020 Medicare physician fee schedule take hold.

Medical practices that use non-physician practitioners (NPPs) may have gotten a little nervous last month when the Medicare Payment Advisory Commission (MedPAC) proposed the end of incident-to billing. Whether CMS accepts the proposal or not, other signs are showing that the feds would like to get all NPP services reimbursed at 85% of the physician rate, regardless of incident-to status.


In perhaps another sign of the growth in services furnished by non-physician practitioners, the SSA is being asked to give equal weight to the medical findings of NPPs when determining whether a person is eligible for Social Security disability payments.

Don’t risk a denial when your non-physician providers bill an annual wellness visit (AWV) and E/M service for the same patient on the same day. Maintain separate documentation of the two components of the visit – one that fulfills the AWV and one that addressed the patient’s unrelated complaint.
Expect the same scrutiny of your non-physician practitioners’ (NPPs’) billing and payments from HHS’ Office of Inspector General (OIG) can as their physician counterparts. Review all six audit targets for NPP services on the OIG's 2013 Work Plan.
These charts represent the E/M utilization for established patient codes (99211-99215) in 2009, 2010 and 2011 for both physician assistants (PAs) and nurse practitioners (NPs). The utilization for each code is presented from left to right in order of 2009-2011. All numbers come from a Part B News analysis of Medicare claims data.

Don’t rush the non-physician practitioner (NPP) hiring process if you want to see the intended workflow efficiencies and financial results. Thorough research of state laws and NPP credentials, complete physician buy-in and clearly delegated tasks are all necessary before you bring on these new providers.


Instruct non-physician practitioners (NPPs) to justify orders for portable X-ray services with written statements about the patient’s need to avoid denials and survive audits. CMS has proposed to expand its policy on who can order mobile X-ray services from just physicians to include podiatrists, dentists and NPPs, according to the proposed 2013 Medicare physician fee schedule.


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