Weekend Clinic

There are times that we have a weekend clinic for patients that need to have a pump removed, or a sequential drug, Neupogen(J1440/J1441), Vidaza(J9025) or Neulasta(J2505) and these drugs are not infusioned but they are given as shots.

Do we have to have a doctor on site when this clinic is going on or it is ok to have the nurse and there be a supervising NP/PA?

Example..

James Smith is a patient of Dr. Jones and he is told he needs to have is Vidaza shot on Saturday, he comes in Saturday for his shot. The nurse gives James his shot, never sees an NP/PA or a Dr and leaves. The nurse then does the billing of the services, nurse visit, admin of drug, and the drug, and bills under Dr. Jones to the commercial insurance company.

I guess my question is...can we bill under the doctor when he/she is not onsite? Dr. Jones in the this case, was not here, but because of the commercial insurance we can not bill NP/PA.

Thank you!

Incident to injections Medicare

A physician is not precluded from billing under the "incident to" provision for services provided by employees whose services cannot be paid for directly under the Medicare program. Employees of the physician may provide services incident to the physician's service, but the physician alone is permitted to bill Medicare. Services provided by employees as "incident to" are covered when they meet all the requirements for incident to and are medically necessary for the individual needs of the patient.

Medicare patients. If the RN, LPN or other auxiliary personnel furnishes the injection in the office and the physician is not present in the office to meet the supervision requirement, which is one of the requirements for coverage of an incident to service, then the injection is not covered. The physician would also not report 99211 as this would not be covered as an incident to service. (Section 30.5 (c))

The CPT manual tells you that physician work related to injections include treatment plan and direct supervision of staff (in office suite).

You must check with commercial payers for their policies on an individual basis.