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Last Modified: 3/4/2018 Location: FL, PR, USVI Business: Part A, Part B

Signature requirements for injections FAQ

Q. When billing Medicare for injections that are provided “incident to” by a nurse practitioner (NP) or other non-physician practitioner (NPP), does the supervising physician have to “sign off” on the injection?
A. No. Although the injections are billed under the supervising physician’s NPI, he or she is not required to see the patient or document any notes in the patient’s medical record.
A service that is billed as “incident to” is one that is furnished as an incidental but integral part of the physician’s professional services in the course of the diagnosis or treatment of the patient’s injury or illness.
Therefore, in order to bill for injections provided “incident to” by an NP or NPP, the following criteria must be met:
Supervising physician must be in the office at the time the injection is given by the NP or NPP
Supervising physician must have established a treatment plan for the condition for which the injection is provided
Documentation contained within the patient’s medical record should demonstrate the “link” between the non-physician’s service and the precedent physician’s service to which it is incidental
Note: If the NP is billing under his or her own NPI, the supervising physician is not required to be in the office -- unless the physician’s presence is required by state law.
Source: The Centers for Medicare & Medicaid Services (CMS) internet-only manual (IOM), Pub. 100-02 Medicare Benefit Policy Manual, Chapter 15, Section 60.1 external pdf file
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