Billing Anti-Coag Clinic

By Pharmacists

Quest ion:

We operate an anti-coagulation clinic which is managed by our pharmacists. Are we able to bill for the pharmacists' time and services? If yes, how do we accomplish this?What services are covered and what are the documentation and coding requirements? Also, do we use professional or facility billing forms?

Answ er:

We do not recommend billing an outpatient facility visit for the services of a pharmacist in evaluating PT/INRvalues of outpatients using anticoagulant medication

Attached is a Q&A we?ve published on the topic of billing hospital visits with pharmacists, as well as our ?Incident To?billing paper

Our updated paper on Coumadin Clinics appears in this issue.

A pharmacist may provide services in a ?freestanding?(not provider-based) clinic under the ?incident to?billing rules. In a non-facility (clinic) setting, it is permissible to report the services of a pharmacist under the NPI of a physician who was primarily responsible for the care of the patient seen on the date of service, provided that all of the following criteria are met:

- Any services performed by the pharmacist are within the State Scope of Practice laws applicable to the pharmacist?s licensure;

- The physician or the organization billing for the physician?s services must incur an expense for the services provided by the pharmacist (and billed under the physician?s NPI);

- The patient must be an established patient, and the diagnosis being treated is not new;