Back to Basics: Can I Charge My Nurse's Services?

July 26th, 2012

The question is one of the most common we hear.  Can I bill for ???? if my RN/LN does it?

The short answer almost every time is, "I don't know, but I'll find out."

CMS calls this the "level of supervision."

The level of supervision required for each service is published by CMS as a part of the Medicare Physician Fee Schedule Database.  To determine the level of supervision for a specific HCPCs or CPT code, please refer to fee schedule look up page of the CMS website at the following address:

https://www.cms.gov/apps/physician-fee-schedule/search/search-criteria.aspx

To locate the supervision level for your code(s) from this website you will need to enter the following information in the sequential screens:

Step 1

  • Select the appropriate year;
  • Select a single, list (up to 5) or a range of procedure codes;
  • Select “Payment Policy Indicators”
  • Select the “Next” button

Step 2

  • Select “Default fields”;
  • Select the “Next” button.

Step 3

  • Enter the HCPC(s) you are researching
  • Select one of the available modifiers or select “all modifiers”
  • Select the “Next” button

The code you have selected will appear on the next page with the corresponding MPFSDB payment policy indicators including “phys supv.”

The numerical indicator will explain the level of physicians supervision needed:  There are basically three levels of physician supervision according to Section 410.32(b) of the Code of Federal Regulations.  They are:

General supervision means the procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. Under general supervision, the training of the nonphysician personnel who actually performs the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician.

Direct supervision in the office setting means the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician must be present in the room when the procedure is performed.

Personal supervision means a physician must be in attendance in the room during the performance of the procedure.

If the level of supervision required is not met, the service will not be considered reasonable and necessary for Medicare payment purposes.

You will need a "key" to understand the number associated with "phys supv" in the fee schedule. The numbers mean:

  • 1 Procedure must be performed under the general supervision of a physician.
  • 2 Procedure must be performed under the direct supervision of a physician.
  • 3 Procedure must be performed under the personal supervision of a physician.
  • 4 Physician supervision policy does not apply when procedure is furnished by a qualified, independent psychologist or a clinical psychologist or furnished under the general supervision of a clinical psychologist; otherwise must be performed under the general supervision of a physician.
  • 5 Physician supervision policy does not apply when procedure personally furnished by a qualified audiologist; otherwise must be performed under the general supervision of a physician.
  • 6 Procedure must be personally performed by a physician OR a physical therapist who is certified by the American Board of Physical Therapy Specialties (ABPTS) as a qualified electrophysiologic clinical specialist and is permitted to provide the service under State law.
  • 6a Supervision standards for level 66 apply; in addition, the PT with ABPTS certification may supervise another PT but only the PT with ABPTS certification may bill.
  • 9 Concept does not apply.
  • 21 Procedure must be performed by a technician with certification under general supervision of a physician; otherwise must be performed under direct supervision of a physician.
  • 22 May be performed by a technician with on-line real-time contact with physician.
  • 66 Procedure must be performed by a physician or by a PT with ABPTS certification and certification in this specific procedure.
  • 77 Procedure must be performed by a PT with ABPTS certification or by a PT without certification under direct supervision of a physician, or by a technician with certification under general supervision of a physician.
  • 7a Supervision standards for level 77 apply; in addition, the PT with ABPTS certification may supervise another PT but only the PT with ABPTS certification may bill.
  • 0 Procedure is not a diagnostic test or procedure is a diagnostic test which is not subject to the physician supervision policy.

 

 

 

Tags: Level of Supervision, Nurse Services,

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