Noridian allows multiple same-day E/M visits, relaxed new patient rules for multispecialty NPPs

by: Julia Kyles, CPC Feb 22, 2022

Noridian has created a way to recognize – and reimburse – nurse practitioners (NP) and physician associates (PA) who provide specialty care for a multispecialty group.

According to the notice “Nonphysician Practitioners (NPPs): Evaluation and Management (E/M) Services”:

“CMS allows one E/M service per beneficiary, per day, per provider specialty type. Since PAs and NPs often provide specialty care (e.g., family practice, psychiatry, orthopedics), multiple E/M services on the same [date of service] may be permissible, when each episode of care is addressing a different clinical condition. The additional E/M service would need to be medically necessary to treat an illness or injury separate from the initial E/M service. A different diagnosis would be required.”

Practices will need to include additional information on each claim to demonstrate the NP’s or PA’s visits were for distinct specialties, according to the Feb. 10 notice.

The policy goes into effect March 1 and will apply to office visits (99202-99215), hospital inpatient visits (99221-99233) and hospital discharge visits (99238, 99239). It does not lift restrictions on multiple E/M visits performed by a physician and NPP or multiple NPPs in the same group.

However, the policy does include a path to more than one new patient visit within the three-year period:

“Example: if the patient was seen in a multi-specialty practice as a new patient by a specialty 50 working within family practice, and then seen within three years by a specialty 50 working within cardiology, the second new visit would be denied without specialty information included in the comment field. If documentation submitted on appeal supported a medically necessary service addressing a distinctly separate problem, the second service may be payable on appeal.”

Noridian, which covers California and a dozen other states, created the policy to ease administrative burden on practices and to “reduce the appeals cause[d] by appropriately submitted services when the specialty and reason for the visit are different between the two E/M services.”

It appears that Noridian is pioneering this policy, so multispecialty practices should stick to the current billing and coding rules if they aren't in Noridian's jurisdiction. But it might catch on.

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Blog Tags: claims processing, NPP

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