Question:
Can a Non-Physician Practitioner (NPP) see patients in a nursing facility without a physician signing each encounter? How do we bill this? Can we do wellness visits in a nursing facility?
Answer:
- Yes, NPPs may care for patients in a nursing home. These can either be billed directly by the NPP, under their own provider number or as shared visits. If the NPP sees patients independently in a nursing facility, they must bill under their own provider number. CMS does not require a counter signature. Of course, the NPP must be practicing in their state scope of practice and must be enrolled in Medicare.
- Mandated visits: Only a physician may bill the initial nursing facility visits 99304-99306 in a skilled nursing facility or nursing facility. (There is an exception to this in a nursing facility when the practitioner is not employed by the facility). A mandated visit may not be performed as a split/shared visit Sometimes, the NPP sees the patient at an earlier date than the physician, who comes and does the admission. The patient is admitted to the nursing facility on Monday, seen by the NPP on that day and seen by the physician later in the week. In that case, the NPP bills a subsequent visit, even though the initial has not been billed. It doesn’t make a lot of sense to bill the subsequent visit before the initial visit, but only a physician may report mandated visits.
- If reporting shared services, be sure all of the requirements are met. Both practitioners must be enrolled in Medicare. Both must participate in the care of the patient on the calendar date. Time or medical decision making may be used to select the level of service. Refer to CodingIntel’s coding guide for Incident to and split/shared services for more detail.
- I am not aware of any restrictions against billing wellness visits in the nursing facility, provided it is appropriate to do a preventive plan for the patient. CMS is silent on this.
Here is a link to the MedLearn matters article. It discusses frequency of mandated physician visits.
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