billing for 96372

[coder218]

We are thinking of starting an injection clinic in one of our outpatient departments located in our facility. We would be billing for the injection only and the injections would be given by an RN. What requirements do we need to be aware of in addition to the direct supervision requirements. Who would be listed as the billing provider?  Since it isn't incident to it doesn't seem correct to bill under the physician although the physician is providing the direct supervision. Any help would be much appreciated. Thank you.

[RichardP]

Billing entities can hire any number of employees to carry out the work.  They can then bill as though they did the work themselves.  So - Billing entity's Type 2 NPI Number for who gets paid.  Type 1 NPI Number for who did the work.  In this instance, it would be the Type 1 NPI Number for the supervising physician.

If the supervising physician is the one who is getting paid, then both NPI Numbers belong to the supervising physician.  If both the supervising physician and the RN are employees of a business entity, then the Type 2 NPI Number (who gets paid) would be that of the business entity.  The Type 1 NPI Number would be that of the supervising physician.

There is a more thorough discussion of this issue somewhere in these threads - but I can't locate it at the moment and don't have time to search more thoroughly.