Section title: Requests for Interpretation
RFI #
1489
2310B NM1 supporting role
Description

As part of a patient’s care management, a PCP requests one of the noted affiliated group practice nonphysician provider types (certified asthma educator, certified diabetes educator, certified health educator, clinical pharmacist, registered dietician, LPN, MS trained nutritionist; respiratory therapist, and RN) to provide patient self management education and training.
The group practice bills the PCP, not the nonphysician provider type, as the rendering because the nonphysician provider type is performing the service in a supporting role. The TR3 does not define rendering physician in the same way that NUCC does with regard to supporting roles (NUCC rendering provider definition excludes supporting roles). Is billing the PCP as the rendering in this situation considered noncompliant with the 837 TR3?

RFI Response

Identifying the PCP as the rendering provider in the situation described is compliant with the 837P. While there is no explicit statement either way, the intent of the authors is to use the same definition for Rendering Provider as is used by the NUCC.

DOCUMENT ID
005010X222