Saint Louis University

Compliance Seminars FAQs

Compliance Seminars FAQs

2015 Mid-Level Providers Seminar Video

Mid-Level Providers: What You Need to Know


Who qualifies as a Non-Physician Practitioner (NPP)?

Physician Assistants, Advanced Practice Registered Nurses, Nurse Practitioners, Clinical Nurse Specialists, Nurse Midwives, Clinical Psychologists, and Physical and Occupational Therapists all qualify as NPPs.

What does the scope of practice for a NPP include?

A NPP is able to perform any professional service delegated to them by their collaborating physician.  For more a more detailed list, refer to presentation slides 11 and 12 for nurse practitioners and slides 17 and 18 for physician assistants.

Does the collaborating physician have to review all of the NPP's records?

No, only 10% of the NPP's records have to be reviewed, 20% if the NPP is prescribing controlled substances.

Does the collaborating physician have to be the one reviewing the records, or can the delegating physicians assist in the process?

A percentage of the NPP's records have to be reviewed every two weeks.  A rotation can be put into place for the collaborating and delegating physicians according to your agreement and departmental needs.

What are the supervision requirements for a NPP?

The supervision requirements differ between nurse practitioners and physician assistants.  Refer to slides 9 and 10 for nurse practitioners requirements and slides 15 and 16 for physician assistants.

Can we continue to bill "incident to"?

No, SLUCare wants NPPs to be able to practice to the full extent of the education and training by evaluation and treating all patient types.  However, split/shared billing is still allowed.

What is split/shared billing?

Billing a split/shared service happens when an E/M is shared between a physician and a NPP from the same group and the physician provides any medically necessary face to face portion of the E/M.  The physician must personally document in the patient's record their face to face portion of the encounter along with the NPPs personal documentation.

Please come back and visit this page as more questions and answers are posted.

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