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One of the most frequently asked questions I get about billing for pharmacist services is "How can a consultant pharmacist use the incident to billing codes in an ambulatory care clinic?"
The easy rule of thumb is to know whether that service is beholden to the direct supervision (aka. Incident-to criteria) or the general supervision requirements.
When implementing a new service as a consultant pharmacist there are a few things to keep in mind regarding the supervision of auxiliary personnel.
1. Incident to billing codes use must fit incident to billing requirements for direct supervision
These services must be performed under direct supervision – The physician must be in the office suite/building.
2. Billed at 100% physician's fee schedule and must be face-to-face.
99211 - nurses' visit - 5 minutes - no medical decision making
99212 - 10 minutes - straightforward/little to no medical decision making
99213 - 15 minutes - low level of medical decision making
99214 - 25 minutes - moderate level of medical decision making
3. Different Medicare Administrative Contractors (MACs) have different requirements regarding auxiliary or non-physician personnel.
Also check your state pharmacy practice act and the language around collaborative practice agreements
Consultant pharmacists can use the incident to CPT codes 99211-99124 to bill through the physician's NPI under the direct supervision of a collaborative physician if the MAC and state's pharmacist scope of practice act allows for it.
What services are you dreaming of implementing in 2019?
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ABOUT THE AUTHOR:
Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website.
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