Hello Holly,
Regarding the documentation and billing for procedures performed entirely by PAs in Oregon, here is a clarified approach that aligns with state laws and Medicare billing guidelines:
- PA Documentation: The PA should fully document the procedure, clearly stating it was performed under the supervision of an IR. According to Oregon law (ORS 677.510), the supervising IR does not need to be physically present but must be available via personal or telephone communication. The PA should sign this documentation as Oregon does not require a co-signature.
- IR Review: Post-procedure, the supervising IR should review and verify the PA's documentation. This can be noted directly in the documentation or through an addendum if the IR agrees or needs to amend any details. This step ensures that the interpretive aspects of the procedure are accurately assessed.
- Final Signature: For procedures with a diagnostic component, the IR should sign off the final report. It's important to state explicitly in the report that while the IR supervised, the procedure was performed by the PA. This ensures the report meets the necessary medical, legal, and billing standards, while the involvement of the IR confirms the interpretive parts of the procedure.
- Medicare Billing: Services rendered by PAs are reimbursed at 85% of the fee schedule amount for the same services provided by physicians, as long as these services are authorized under state law. Ensure that billing reflects the PA's role and the supervision conditions accurately.
- Education and Communication: Maintain regular training for staff on these documentation and billing practices to avoid coding errors and ensure compliance with state and federal regulations.
Incorporating the information you provided, the outlined steps ensure adherence to Oregon state laws and Medicare billing requirements, providing a robust framework for your practice's compliance and operational efficiency.
Resources:
https://www.ama-assn.org/sites/ama-assn.org/files/corp/media-browser/public/arc-public/state-law-physician-assistant-scope-practice.pdf
https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c23.pdf
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Laura Manser, CPC, CPMA, CEMC, CIRCC, RCC
Director of Provider Education
PBS Radiology Business Experts
lmanser@pbsradiology.compbsradiology.com
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Original Message:
Sent: 04-30-2024 16:30
From: Holly Wallner
Subject: IR PA procedural billing question
Hi All,
Documentation clarification for procedures performed entirely by the PA and may have an interpretive component, e.g. port checks, abscess tube checks, biliary tube checks, nephrostograms. etc. In this case, we suggest the following flow when a PA is entirely performing procedures.
This is what I came up with:
- PA dictates and signs off final report for proper billing under PA name
- PA dictation states the procedure was performed entirely by the PA with direct/personal supervision by the IR Rad
- PA assigns the case to IR in PACS
They think this:
For procedures with diagnostic components, the PA dictates the procedure but does not sign it.
The PA assigns the study/dictation to the rad.
The rad reviews, changes if necessary and signs it off
When the later happens, the report comes over with the IR name as the performing clinician, which is incorrect and could be missed by a coder. Is it appropriate to have the IR sign off but make it clear in the report that the procedure was personally performed by PA x under Dr. X direct supervision?
TIA for any input you can provide!
Holly
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Holly Wallner
Practice Administrator
TRG, LLC
Portland, OR
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