Your chances of getting audited for your non-physician practitioner (NPP) claims continues to climb – especially your incident-to claims. CMS is just waiting for you to slip up. I found these NPP/incident-to related cases on the Office of the Attorney General (OIG) website. I was floored by the size of the penalties.
Pretty eye-opening stuff…
• $1,500,000 = A doctor in NJ gets hit hard for billing for “incident to” services while he was not in the State.
• $395,591 = A Rural Health Center in AR got hit with a penalty of for improperly billing separately for “incident to” services
• $379,085 = A two-physician practice in FL must pay for billing incident-to services when the requirements were not met.
• $162,676 = A physician in MA agreed to pay for submitting claims under his billing number for services actually provided by nurse practitioners.
The common thread in all of the above cases is incident-to billing and supervision. This proves you can’t afford to file one more incident-to claim without being absolutely sure you’ve got it down. But this isn’t the only reason why billing for incident-to services correctly is essential. In addition to getting audited and fined, failing to because they’d be taking a 15% reimbursement hit right to their bottom line (instead of getting paid 100% of the physician rate, you’d only be paid 85%).
But Submitting accurate, compliant incident-to claims is a significant challenge. Here is a small sampling of the confusion surrounding billing for incident-to services for your NPP:
• If the doctor is upstairs and the NPP downstairs, can you still bill incident-to?
• Can the NPP see new patients and bill incident-to?
• What if the patient is seen by an NPP for an existing problem, and then introduces a new problem during the exam, what then?
Submitting your NPP claims incorrectly really isn’t an option any longer considering the potential of hefty fines. You certainly don’t want to end up on the OIG’s radar like the practices above did.
Call Unify today to provide you education and an audit of your practice to make sure that your practice is following the guidelines–before the OIG does.
