Kathleen Schaum has a new article in Advances in Skin and Wound care: Exercise Caution: Before Asking and Answering Reimbursement Questions on the Internet. The purpose of her article is to point out the dangers of answering billing and coding questions without obtaining specific details around the clinical context. She provides the example of a “mobile” practitioner who sent a registered nurse (RN) to the patient’s home to apply a cellular and/or tissue-based product (CTP)/CAMP — which he thought was acceptable under Medicare rules because the nurse was providing services “incident to” the physician.
Ms. Schaum explains that the application of a Cellular Tissue Product (CTP) / skin substitute, a surgical procedure, is out of the scope of a registered nurse and thus the physician cannot bill for a skin sub application if applied by a nurse. Ms. Schaum goes on to explain the rules around supervision of auxiliary personnel outside of the office-based setting.
I am aware that some mobile groups are also allowing Emergency Medical Technicians (EMTs ) to apply skin substitutes in the home setting. I encourage mobile practices to read Ms. Schaum’s article carefully!
Caroline
