Circumstances:
– Nurse Practitioner sees patient at a Facility Based clinic for Breast Health (for high risk or benign patients)
– After exam, she determines patient needs a surgical intervention
– She bills new patient visit independently
– She refers the patient that requires surgical intervention to a surgeon employed by the same group under the same TIN.
– Nurse Practitioner has a different Taxonomy code (for specialty and sub specialty) than the surgeon
– Nurse Practitioner sees patient at a Facility Based clinic for Breast Health (for high risk or benign patients)
– After exam, she determines patient needs a surgical intervention
– She bills new patient visit independently
– She refers the patient that requires surgical intervention to a surgeon employed by the same group under the same TIN.
– Nurse Practitioner has a different Taxonomy code (for specialty and sub specialty) than the surgeon
In this circumstance, can the surgeon bill this visit as a new patient visit as well? Does this constitute a compliance issue or anti Stark issue? Especially if the same NP is assisting the surgeon with dictations and exam on her non practice days?