Guidelines for Reimbursement for Limited Licensed Practitioners Billing guidelines for Limited Licensed Practitioners, such as nurse practitioners, physician assistants, certified nurse midwives, were reviewed and approved by the Compliance Steering Committee. The guidelines are: 1. Obtain provider identification numbers for all LLP providers. Provider numbers are necessary for both independent and "incident to the physician's service" billing; 2. Bill only for services provided by LLPs who have independent provider numbers, and who do not appear on a facility cost report, (e.g. who are not hospital employees); 3. Bill only for professional services that are separately provided by the LLPs. Duplicate services provided by an LLP and the physician on the same day are not separately billable; 4. Periodically review payer regulations and reimbursement for LLPs for accurate reimbursement; 5. Periodically review the quality and content of the supporting documentation for the level of service submitted for reimbursement basis. Clarification of the "incident to the physician service" provision for billing The "incident to" the physician's service provision may not be applicable to managed care insurance programs. The physician must see the patient initially to establish the course of treatment and care. The services may be part of a course of treatment. "Incident to" services are only payable in the office setting, and not applicable to either the in-patient or the out -patient hospital places of service. Direct supervision by the physician means that the physician who is billing for the service must be on the floor, or office suite, immediately available, for guidance, direction, and supervision. The employee may be a leased employee from another entity. This allows for the billing of services provided by employees that The University has established a "pass through" for their entire salary line. However, if the employee is also reported on a "cost report" by the leasing entity, (the hospital), "incident to" services are not billable. The "incident to" services should be submitted using the lowest CPT Evaluation & Management code for established office patients - 99211. Counseling and coordination of patient care may be incorporated into the service provided. However counseling and coordination of care cannot be considered as part of a documentation review assessment of the level of service code. Many LLPs have specific government regulations for payment of services. The Office for Billing Compliance is available for additional information as required. Billing comparison of "Incident to the physician service" to Direct Billing for LLPs To Bill as "Incident To" To Bill as Independent Provider Non-Facility Employee Non-Facility Employee MD initiated care Service provided by the LLP Subsequent Office service Individual PIN Direct employee or Leased employee Any Place of Service Submitted code = 99211 Any Category or Level of CPT code   Return to Contents | Return to Billing Compliance