Medicare allows for provision of services and procedures by enrolled, licensed physician assistants.
A licensed physician assistant is an investment of your time, money, and reputation. Are physician assistants (PAs) in your practice giving you the best possible return on your investment? There are many ways to look at this, but one of the most often overlooked is in the Medicare arena. Do the PAs in your practice have a National Provider Identification number (NPI) number and are they enrolled in Medicare? If not, there may be Medicare dollars left on your table.
Medicare allows for provision of services and procedures by enrolled, licensed PAs. In the course of a day, a licensed PA can see the same kinds of patients as the physicians in your group, billing under their own NPI. New patients, returning visits, consults, preoperative and postoperative visits, acute fractures and follow-up exams are billable and reimbursable for PAs under Medicare guidelines. Physician assistants also can see patients in clinic, the hospital, nursing homes and patient homes. They can diagnose, treat, prescribe, apply and remove casts, perform joint injections and other minor procedures, and first assist in surgery – all under their own NPI numbers.
Because of their medical training and background, PAs are not required to have an onsite physician when they provide these billable and reimbursable services. As dependent practitioners with physician supervision and oversight, PAs become true extenders of your practice, maximizing the use of everyone’s time and talents.
Medical and surgical services
Jennifer Van Atta
Medicare pays a PA’s employer for medical and surgical services by the PA at 85% of the physician rate, in virtually all practice settings. Medicare has specific rules and claim submission instructions for PA services, but generally defers to state licensing and supervision requirements. Note that supervision requirements vary by state. The requirements may include, for example, physician chart review of a certain percentage of the patients seen by the PA in a month, and direct communication between PA and physician, such as via telephone or electronic communication. Your state may be more lenient or more restrictive. Be sure to check on your state’s rules and regulations regarding supervision of physician assistants. Medicare, however, does not have a requirement that the physician see the PA’s patients, and does not require that the physician be physically on site when services are provided.
From a rough cost-benefit standpoint, if a licensed PA bills Medicare for their services under the PA’s NPI number, then the PA becomes a revenue stream of 85% of the physician rate for the practice, at a fraction of the salary cost. Far from limiting the practice, a licensed PA doesn’t take the place of a physician, but instead extends the physician’s services for a greater return on investment.
Some practices are in the habit of billing for PA services as “incident-to,” under the physician’s NPI number. Incident-to billing is a lengthy article in and of itself, but suffice it to say for now that this is not the best way to bill in your practice. In fact, incident-to billing has become high risk for the PA, physician and practice because the Medicare criteria for incident-to visits are specific. In addition, documentation for these visits must be perfectly matched to Medicare incident-to requirements. Failure to meet criteria to the letter or failure to document correctly could leave your group exposed to accusations of Medicare fraud. The American Academy of Physician Assistants recommends billing under the PA’s NPI for work performed and services rendered by the PA.
Time, money and education
How do you start to take advantage of the dollars that might be left on your table? Make sure your PAs have an NPI number because that is the starting gate for Medicare. The NPI number is required for health care professionals by Medicare before enrolling as a provider. Next, file an 855i application to enroll the PA as a Medicare provider. Set aside time to meet with your billing and coding specialist. Talk about the Medicare billing requirements. Confirm they are updated on the way to bill correctly for all PA services provided in your various settings, including first assisting.
Your PA is an investment of your time, money and reputation. Make sure you are getting the most out of your investment in your PA.
For more information:
- Jennifer Van Atta, MS, PA-C, is the key contact for orthopedic services at a jointly sponsored clinic in The Dalles, Oregon, developed in cooperation with Mid Columbia Medical Center and Oregon Health & Science University. She can be reached at MCMC/OHSU Orthopedic Services, 551 Lone Pine Blvd., The Dalles, OR 97058; 541-506-6500; email: firstname.lastname@example.org.
- Disclosure: Van Atta has no relevant financial disclosures.