Direct Supervision Requirements for Incident to Services Performed by Certified Registered Nurse Practitioners (CRNPs) and Physician Assistants (PAs) in Response to COVID-19 (Updated April 16, 2021)
00.10.40d Incident to and Non-Incident to Services Performed by Certified Registered Nurse Practitioners (CRNPs) and Physician Assistants (PAs)
The purpose of this News Article is to provide advance notice regarding direct supervision requirements for Incident to services performed by Certified Registered Nurse Practitioners (CRNPs) and Physician Assistants (PAs) in response to Coronavirus Disease 2019 (COVID-19).
This communication addressing direct supervision requirements for Incident to services performed by Certified Registered Nurse Practitioners (CRNPs) and Physician Assistants (PAs) is effective from March 6, 2020 and will be reevaluated for continuing applicability on June 30, 2021.
There is currently an outbreak of respiratory disease caused by a novel coronavirus, which has now been detected internationally. The virus has been named “SARS-CoV-2” and the disease it causes has been named “Coronavirus Disease 2019 (COVID-19)." The SARS-CoV-2 virus has demonstrated the capability to rapidly spread, leading to significant impacts on healthcare systems and causing societal disruption. The potential public health threat posed by COVID-19 is high globally. To effectively respond to the COVID-19 outbreak, rapid detection of cases and contacts, appropriate clinical management and infection control, and implementation of community mitigation efforts are critical.
To help reduce potential exposure risks to members and health care providers the definition of direct supervision has been modified to include direct supervision by virtual presence. .
On an interim basis and for the duration of the COVID-19 public health emergency, the Company's definition of direct supervision for Incident to Services has been revised to indicate that the necessary presence of the physician for direct supervision includes virtual presence through audio/video real-time communications technology when use of such technology is indicated to reduce exposure risks for the member or health care provider.
All other criteria for services to be recognized as "Incident to" must be met, and include:
The individual's medical record must reflect the medical necessity for the care provided. These medical records may include, but are not limited to: records from the professional provider's office, hospital, nursing home, home health agencies, therapies, and test reports.
The Company may conduct reviews and audits of services to our members, regardless of the participation status of the professional provider. All documentation is to be available to the Company upon request. Failure to produce the requested information may result in a denial for the service.
For "Incident to" services performed by a CRNP or PA, the supervising physician should bill using their own National Provider Identifier (NPI) and report modifier SA.
Dosing and Administration
Black Box Warnings and/or Contraindications
- The individual seeking treatment must be an established patient, and the service must be treatment for an existing problem.
- The treatment course must have been initiated by a physician at a previous encounter.
- The service must be an integral part of the patient's course of treatment.
- The physician must remain involved in the treatment plan.
- The service must be of a type commonly furnished in a physician’s office or clinic (not in an institutional setting).
- The service must be an expense to the physician's practice.