Preceptor Preparation Online Course - Advanced

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Module 7: Legal and regulatory Considerations for the Preceptor

Billing/coding and documentation guidelines for preceptors and APRN students

Per Nurse Practitioner (NP) Attorney Carolyn Buppert: "Student services are not billable; however, students may perform and document certain portions of the history. A student may perform and document the past medical history, past social history, family history, and review of systems."

At present, there is no specific legislative payment mechanism for NP students to have their services covered. Within the Medicare program, a lack of specific coverage authority tends to equate to a lack of coverage. According to CMS Regulations medical students are able to perform the past, family and social history, and the review of systems. The student's preceptor must review the information that is collected by the student before it can become part of the official medical record. This work performed by the student can then become part of the medical documentation for the preceptor's billing purposes. Regarding evaluation and management services, the Medicare program has indicated that the service provided by a medical student is billable under the preceptor if personal supervision (in the same room) is provided when the student is performing the service (section 15016 of Part 3 of the Medicare Carriers Manual). It is generally held belief in the NP community that this is also true of NP students.

While not officially approved by the Medicare program, the following items should guide billing while precepting students:

  • The authorized Medicare practitioner/clinical preceptor is ultimately responsible for assuring the highest quality patient care;
  • The authorized Medicare practitioner/clinical preceptor is the only individual who can submit a claim for care delivered to Medicare beneficiaries;
  • The clinical preceptor's responsibility is to ensure that the appropriate standard of care is received by the patient;
  • On each visit where services are provided, the patient should always be personally seen and treated by the clinical preceptor;
  • The clinical preceptor must supervise the activities of the student;
  • NP students are not covered under the teaching physician /resident billing rules. The Medicare authorized practitioner/clinical preceptor must always supervise and/or provide the necessary components of a given service provided to the Medicare beneficiary.

Students who are obtaining a second advanced nursing license or a post-masters degree or certificate to become eligible for certification in a second population specialty, must be very cautious that their student clinical hours completed are not done for compensation and are approved and supervised by their program of study.

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