Morning,
Over the years my partners and I have had conversations about the utility of mid-level providers in anatomic pathology. By mid-level providers we mean licensed ARNPs and Physician Assistants (PA's) ; not Pathologist's' Assistants. We don't know of any groups that do this. Right now, this is more of a thought experiment.
We usually discuss two separate scenarios:
1. Can a licensed mid-level practitioner be the rendering provider and bill Medicare and commercial payors for 88300-88365 codes? I know the AFP Pathology Service Coding Handbook addresses "Clinical Scientists (PhD)" not being able to bill for professional services but it is less clear about ARNP and PA's.
- The scenario was that group practice of pathologists would spend several years training a licensed mid-level provider on how to work up cases, diagnose cases, determine medical necessity for stains, etc. We would have a robust analytic and post-analytic QA system in place.
- Could a mid-level be the rendering provider independently for the surgpath codes?
- Are there rules (CMS, payor, or state) that specifically prohibit mid-levels from billing surgpath codes?
- Malpractice?
- Would a physician cosign be necessary?
2. The discussion that comes up more frequently is: Would a pathology group be able to train a mid-level provider, histotechnologist, or even someone with graduate-level biology-related degrees to screen cases and work them up for an attending pathologist? This would be similar, I suppose, to the way that fellow/resident physicians may preview, order stains, and prepare a case for signout before showing it to the attending. Or a tech looking at a bad IHC and reflexing a do-over.
- The pathologist would then look at the case, take into consideration the mid-level's impression, interpret (or discard) special stains, render a diagnosis, and issue a report in the pathologist's name. The previewer would not be referenced in the final report or paper records.
. The purpose of this would be to increase pathologist productivity by training someone to preview and work up cases.
- Competency assessment by direct observation would be extensive,
is anybody out there doing this?
Over the years my partners and I have had conversations about the utility of mid-level providers in anatomic pathology. By mid-level providers we mean licensed ARNPs and Physician Assistants (PA's) ; not Pathologist's' Assistants. We don't know of any groups that do this. Right now, this is more of a thought experiment.
We usually discuss two separate scenarios:
1. Can a licensed mid-level practitioner be the rendering provider and bill Medicare and commercial payors for 88300-88365 codes? I know the AFP Pathology Service Coding Handbook addresses "Clinical Scientists (PhD)" not being able to bill for professional services but it is less clear about ARNP and PA's.
- The scenario was that group practice of pathologists would spend several years training a licensed mid-level provider on how to work up cases, diagnose cases, determine medical necessity for stains, etc. We would have a robust analytic and post-analytic QA system in place.
- Could a mid-level be the rendering provider independently for the surgpath codes?
- Are there rules (CMS, payor, or state) that specifically prohibit mid-levels from billing surgpath codes?
- Malpractice?
- Would a physician cosign be necessary?
2. The discussion that comes up more frequently is: Would a pathology group be able to train a mid-level provider, histotechnologist, or even someone with graduate-level biology-related degrees to screen cases and work them up for an attending pathologist? This would be similar, I suppose, to the way that fellow/resident physicians may preview, order stains, and prepare a case for signout before showing it to the attending. Or a tech looking at a bad IHC and reflexing a do-over.
- The pathologist would then look at the case, take into consideration the mid-level's impression, interpret (or discard) special stains, render a diagnosis, and issue a report in the pathologist's name. The previewer would not be referenced in the final report or paper records.
. The purpose of this would be to increase pathologist productivity by training someone to preview and work up cases.
- Competency assessment by direct observation would be extensive,
is anybody out there doing this?
