Disclosures: DePalma and Zuber report no relevant financial disclosures.
August 12, 2021
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Physician assistants will benefit with direct pay under CMS proposed rule

Disclosures: DePalma and Zuber report no relevant financial disclosures.
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In its proposed rule for the 2022 Physician Fee Schedule, CMS includes a section on billing for physician assistant services. It has people talking, but few know what it does – and does not – mean.

If approved as a final rule, physician assistants (PAs) may choose to bill Medicare and be paid directly for their services, reassign their payment and incorporate as a solo or group practice comprised solely of PAs.

This has long been true for physicians, nurse practitioners, dieticians, social workers and others. This change adds PAs to those who can bill Medicare directly.

Sondra DePalma
Sondra DePalma
Kim Zuber
Kim Zuber

The 2022 Physician Fee Schedule proposed regulatory changes would align policies with the Federal statute of the Consolidated Appropriations Act of 2021. The act amends the Social Security Act and removes the requirement that payment for services performed by PAs be made to their employer and allow payment to be made directly to a PA.

Section 403 of the Consolidated Appropriations Act of 2021 amends section 1842(b)(6)(C)(i) of the Social Security Act and removes the requirement that payment for services performed by PAs be made to their employer.

This will authorize PA-owned corporations to receive payment from Medicare and allow flexible employment models that require reassignment of payment.

Medicare payment rate

What does this mean to a nephrology practice? Most PAs and practices that employ PAs will not be affected or notice any change in billing or payment. Why? The amendment is a statutory change in the Medicare payment arrangement only. It does not change the Medicare payment rate for PAs (ie, 85% of the amount paid to a physician), the types of services PAs are authorized to perform or any other Medicare billing policy (eg, “incident to” and split services).

Unless PAs choose to receive payment directly or reassign their payment to someone other than their current employer, no action by PAs or their employers needs to be taken. PAs and their practices do not need to obtain a new National Provider Identifier (NPI) number or re-enroll with CMS.

Likewise, the existing Medicare enrollment status of PAs with payments to their employers will remain in effect unless a change of assignment is desired and made. In fact, the regulatory change will take place and some PAs and employers will not even notice it. The new law and policies also do not directly affect Medicaid or commercial payers, and do not supersede any state law restrictions.

Within nephrology practices, billing will remain the same. NPs have always had the ability to receive direct payment or reassign payment to a third party, but most reassign payment to their employer because most employers require providers to reassign their payment to them.

Patient rounds

Billing policies and payment for nephrology services will not be changed by the new law and regulations. Hemodialysis rounds may continue to be billed under the physician’s NPI if the complete assessment and establishment of the plan of care are done by the physician. Rounding done for patients on peritoneal dialysis, even when done by a PA or NP, may be billed under the physician’s NPI when the PA/NP follows “the physician plan of care.”

Instances in nephrology where this billing change may make a difference is if PAs would like to own their own corporation or nephrologists would like to contract with PAs they do not employ but wish to have them reassign their payment to them.

Most practices and PAs will continue to provide care and bill for services in the same manner they have been used to doing for years. PAs will continue to practice autonomously and collaboratively as members of health care teams.

The proposed rule is open for comment until September 13 at www.regulations.gov.

For more information:

Sondra DePalma, DHSc, PA-C, DFAAPA, is director of regulatory and professional practice for the American Academy of Physician Assistants, based in Alexandria, Virginia. She can be reached at sdepalma@aapa.org.

Kim Zuber, PA-C, is the executive director of the American Academy of Nephrology Physician Assistants and is based in St. Petersburg, Florida. She can be reached at zuberkim@yahoo.com.