PA billing incident to in SNFs?

Hi all,

Can a PA bill incident to in a skilled NF, CPT 99309? We are in Maryland. It is unclear if the supervision is general or direct. Medlearn Matters #R808CP states general. Just not comfortable making this call and etching it into stone at our billing company.

Any suggestions or references much appreciated.

Thank you,

Mary Flanery, CPC, CBCS, CHC
Quality Review Specialist
MedStar Physician Billing Services

MedStar Health is a not-for-profit, integrated healthcare delivery system, the largest in Maryland and the Washington, D.C., region. Nationally recognized for clinical quality in heart, orthopaedics, cancer and GI. IMPORTANT: This e-mail (including any attachments) may contain information that is private, confidential, or protected by attorney-client or other privilege. If you received this e-mail in error, please delete it from your system without copying it and notify sender by reply e-mail, so that our records can be corrected. Thank you. Help conserve valuable resources - only print this email if necessary.


  • From Medlearn
    Hospital or SNF
    For inpatient or outpatient hospital services and services to residents in a Part A covered stay in a SNF the unbundling provision (1862 (a)(14) provides that payment for all services are made to the hospital or SNF by a Medicare intermediary (except for certain professional services personally performed by physicians and other allied health professionals). Therefore, incident to services are not separately billable to the carrier or payable under the physician fee schedule.

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    Maxine Lewis, CMM, CPC, CPC-I, CCS-P, CPMA
    Main: 513-771-7070
    Direct: 513-672-4363
    Fax: 513-326-7640
    200 Northland Blvd
    Cincinnati, OH 45246

  • Hi Maxine,

    I did find that, thank you. I assume the 99309 is being billed under Part A, or could it be Part B? I’m just not experienced enough with this side of billing. Any suggestions?

  • ​It depends upon the status of the patient whether Part A or B.

    Maxine Lewis, CMM, CPC, CPC-I, CPMA, CCS-P

    Main: 513-771-7070
    Direct: 513-672-4363

    Fax: 513-326-7640

    200 Northland Blvd

    Cincinnati, OH 45246

  • If this is regarding PA’s providing E/M services, and other applicable PFS services, incident to a physician in a nursing facility; it doesn’t matter if the patient is in a part A stay or a part B stay…incident to is not allowed unless the supervising physician establishes an office within the facility and is present within that suite while the PA is seeing the patient in that same suite. If that were the case, then the location of service becomes the nursing facility, but the place of service is 11 because it’s the office suite.

    Heres’ the excerpt from R808CP:

    “E - Incident to Services Where a physician establishes an office in a SNF/NF, the “incident to” services and requirements are confined to this discrete part of the facility designated as his/her office. “Incident to” E/M visits, provided in a facility setting, are not payable under the Physician Fee Schedule for Medicare Part B. Thus, visits performed outside the designated “office” area in the SNF/NF would be subject to the coverage and payment rules applicable to SNF/NF setting and shall not be reported using the CPT codes for office or other outpatient visits or use place of service code 11.”

    Or are you billing for the nursing facility itself?


    Kris Cuddy, CPC, CIMC
    Healthcare Compliance Analyst
    Compliance Office
    Michigan State University HealthTeam
    East Lansing, MI
    Ofc: 517-355-4547
    Fax: 517-353-5292

  • It don't think it is possible for PA to bill incidental services in a SNF
    facility. If he/she is certified RN then can directly bill. We were billing
    for NP group in 2 states in a SNF facility.

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