In 2014, the CMS has defined for everyone what advanced practice nurse would look like or the physician assistant would look like under the category of non-physician practitioners or non-physician qualified professionals. And what they're talking about is a person who is qualified either by their education, training, license, having privileges in a facility that performs a professional service that is within the scope of practice for the person who has this licensure and independently reports that professional service.
Usually we consider independently reporting as that this person can bill for it. We know that in some circumstances, nurse practitioner for instance is not allowed by the payer to bill independently for their services even though they would qualify under all of these other definitions. That still does not mean that they have not met the definition of an advanced practice nurse for this particular definition in CPT.
The other important point is that these advanced practice nurses and physician assistants are considered as working in the exact same specialty and subspecialties as the physician they are working for. So in other words, this may impact you in that you have someone working in just say general Ob and you have a nurse practitioner whose specialty happens to be pain – liver pain medicine for instance. You don’t get to assign this person as being in different subspecialty and different specialty. And that definition of course leads you to the definition of a new versus an established patient in that it has to be a person who was not seen within the last year for the practitioner who is in the same specialty or subspecialty.
So this is going to have some minor implications to coding. But at any way, they have added this to the book. And they've separated this out from the definition of what they're calling clinical staff. In this case, a clinical staff person is somebody who works under the supervision of a physician or another qualified healthcare professional who is allowed by law, regulation, facility policy to perform or assist in the performance of a professional service but they do not individually report that service.
So generally speaking, the thing that comes to mind instantaneously would be an RN. An RN is allowed to work under the supervision of another practitioner who is licensed to bill for a service but cannot by themselves report the service independently.
But by this definition, you would kind of say, “If a nurse practitioner is the one who is working under the supervision of the physician and cannot independently report that service would they then not be referred to as clinical staff.” We think it's a fine hair that we're splitting here. But CPT felt that this was a necessary distinction to make. But the main thing is to make sure that when you are billing your payers, you have a distinct definition from them on who can bill and who cannot separately bill.
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