FQHC Billing question: Direct supervision for mid level providers?
To your question, please remember that the “incident to” guidelines pertain only to Medicare in the fee-for-service (FFS) world in terms of using a different NPI. In a FQHC, Medicare is payable via the encounter rate which is based on face-to-face encounter between a patient and a “core provider.” The core provider can be a physician or a “non-physician practitioner” (NPP). A NPP is defined as a Nurse Practitioner, Physician Assistant, or Certified Nurse Mid-wife. There is no reduction in payment (as in the FFS world) world when being compensated for “encounter rate.” Further, the restrictive “incident to” guidelines are Medicare FFS only which means you should not automatically apply these to Managed Medicaid, encounter rate (PPS) Medicaid, or other commercial plans unless you determine, in writing, that they follow Medicare’s explicit statutes. However, since the Medicare “incident to” guidelines are quite conservative, it is a very safe way to interpret how to bill a NPP under a doctor’s NPI.