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Compliance concerns for billing nurse practitioner and physician assistant services

Cynthia Swanson (cswanson@seimjohnson.com) is a Senior Manager in Healthcare Consulting at Seim Johnson, LLP in Omaha, NE.

Billing Medicare for services performed by nurse practitioners (NPs) or physician assistants (PAs) seems fairly straightforward. It should be noted, however, there are three options for reporting/billing NP and PA services to Medicare. To assist with ongoing compliance efforts and risk minimization, each option requires a clear understanding of Medicare’s guidelines. To bill under their own names, NPs and PAs must have their own National Provider Identifier (NPI) number.

What are the three options for reporting/billing NP/PA services to Medicare?

  • Report as an “incident-to” service

  • Report as a split/shared service

  • Report under the NP’s name/NPI or PA’s name/NPI

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