Services Involving Non-Physician Practitioners – ARNPs and PAs

Office of Physician Billing Compliance, Gainesville, Florida
September, 2014

Reviewed December 2014

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Clinic visits only – if you are in the clinic suite for the entire time the patient is seen by an ARNP or PA, sign both the billing authorization as “billing provider”, and the medical record within 24 hours of the service.

Inpatient services only – you may combine your physician note with an ARNP or PA note in support of a single E&M service. You must specifically reference the ARNP PA note (or add an as an addenda), including a concise but patient specific comment, personally stating that you saw and evaluated the patient and electronically sign your note. You may not combine services that are based on combining times, or bill for procedures performed by the NPP.


Clinic visits only– document the service in the electronic health record.

  • If you are seeing the patient with no physician in the clinic suite or intend to bill independently in your (ARNP/PA) billing number, sign the medical record and encounter form as “service provider” – do not forward the note or encounter form for physician signature.
  • If a physician is in the clinic suite for the entire service (including both E&M and procedures), forward documentation to the physician to sign the medical record and the encounter form as billing provider (physician must sign within 24 hours. Indicate on the encounter form, if “incident to” is met or not for all services/all payors.
  • ALWAYS sign the encounter form and medical record for all services in which you are involved

Inpatient services only – if you provided the service, document and sign the note to be submitted in your billing number. Note: the physician sees and evaluates the patient, they may also use your documentation in support of a combined E&M – both notes must be written on the same date (date of service). Physicians may not bill for inpatient procedures performed by you or combine times for time based codes such as critical care or other E&M services based on time.

Teaching physician documentation rules do not extend to ARNPs or PAs – do not use Resident documentation to support an ARNP/PA service.

Staff keying from encounter forms/chart abstractors

Clinic services where an ARNP or PA has signed the encounter form (or you have knowledge they were involved in the service):

  • Medicare –
    • ALL NEW patient services and services that are indicated as NOT “incident to” must be billed in the ARNP PA billing number, even if a physician also saw and evaluated the patient.
    • Services meeting “incident to” can be billed in the physician’s billing number.
  • All other payors – bill in the physician’s billing number.

Inpatient services – E&M services with appropriate combining language may be submitted in the physician’s billing number. All other services must be submitted in the ARNP or PA billing number.

Required Billing Edits

  • Billing edits must be in place to identify services that
    1) identify both a billing provider and service provider, where one of the providers is an ARNP or PA;
    2) the service is new and;
    3) the payor is either originally identified as Medicare or changed to Medicare.

    All these services must be submitted in the ARNP/PA billing number.

  • An individual must be assigned to review this edit and make these corrections monthly.
  • A supervisor must confirm this review is completed timely.

If you have any questions about this tip, or another compliance concern,
the Office of Compliance for the College of Medicine is here for you.
Please call (352) 265-8359 or e-mail Nina Tarnuzzer at


Webmaster, College of Medicine, Office of Physician Billing Compliance
Page created 11/20/2014. Reviewed December 2014.