Physicians Practice - September 2008 - (Page 81) CODING YOUR TOP CODING CONCERNS SOLVED CAN YOU BILL FOR STUDENT-PROVIDED SERVICES? BY BETSY NICOLETTI Here’s a common question: “Can you bill if a nurse practitioner (NP) mentors an NP student and the student performs a service, documents it, and the NP signs off?” The answer is easy: No. Services provided by medical, NP, or physician assistant students are never billable services. These students are unlicensed and uncredentialed. You can’t bill a government payer or a third party payer for services performed or documented by any kind of student. medical, family, and social history. The billing provider must tie that portion of the history to her own note in order to count it as her own documentation. For example, write, “The remainder of the ROS and PFSH was documented by my student today, and I reviewed and agree with it.” It is never acceptable to bill for services based on any student note except in those very limited ROS and PFSH situations. Remove the phrase “seen and agreed” from the lexicon in a physician practice. CAN’T DO IT Services provided by medical, NP, or physician assistant students are never billable services. The usual response: “But our NP sees all of these patients. She goes in, examines the patient, and develops the plan. Then the student writes it all down and the NP signs it. Isn’t that OK?” No. The credentialed and qualified NP may bill only for those services she personally performs and documents. The NP may not bill for services performed by the student. Grasping for straws, the final question is, “Isn’t there anything we can use from the student’s documentation?” Sure. A student, like any staff member in the office, may document a review of systems and past WWW.PHYSICIANSPRACTICE.COM Most groups allow and encourage the student to fully document the note. However, they base the billing on the fully documented note of his credentialed and licensed provider. RULES FOR TEACHING PHYSICIANS IN SURGERY The teaching physician rules allow an attending physician to bill for services provided or partially provided by residents in an approved Graduate Medical Education program. (See the CMS Claims Processing Manual, Publication 100-04, Chapter 12, Section 100. Note that Medicare uses the terms “teaching physician” and “attending physician” interchangeably in their manuals.) However, what’s required of the attending physician and in the documentation varies by the surgical service provided. Minor surgical procedures are defined as procedures that take less than five minutes to perform. In order to bill for minor surgical services performed by a resident, the teaching physician must be present the entire time. The resident or nurse may document the teaching physician’s presence. Minor surgical procedures performed by a student are not billable services. For endoscopy, the teaching physician must be present in the room for the entire procedure from the time the scope is inserted to the time the scope is removed. The attending should document his participation in the care. Major surgical procedures require the teaching physician’s presence during key or critical portions of the procedure. The teaching physician decides which part of the procedure is key or critical. Only the teaching physician can document his participation in the care. The resident can’t document it instead. The teaching physician also has to be immediately available for the entire procedure in order to provide assistance, should that be necessary. Apply modifier GC to these services. This modifier tells Medicare that the services were performed under the teaching physician rules; it does not affect payment. • Betsy Nicoletti, MA, CPC, is the author of “The Field Guide to Physician Coding” and “The Physician Auditing Workbook.” More coding information can be found at her Web site, www.mpconsulting.org or via editor@physicianspractice.com. SEPTEMBER 2008 | PHYSICIANS PRACTICE | 81 http://www.mpconsulting.org http://WWW.PHYSICIANSPRACTICE.COM
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