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CMS staffers confirmed this week that MACs can determine whether they’ll allow licensed practical nurses (LPNs) and registered nurses (RNs) to perform annual wellness visits (AWVs) and collect from Medicare for those services. That’s the word from a Feb. 22 CMS Open Door Forum, where providers called in with several questions affecting Part B providers.
One caller phoned into the forum to ask about a Q&A posted on the Web site of WPS Medicare, a Part B payer in four states, which asks whether an RN or LPN can perform “the entire annual wellness visit (AWV, G0438-G0439).” WPS responds on the site, “Yes, an RN or LPN can perform the visit. They need to be under the direct supervision of a physician and the state license needs to allow for them to do all the ocmpoennts of the service.” (http://www.wpsmedicare.com/part_b/education/awv-faq.shtml). The caller asked whether this is a general CMS policy or if it only applies to WPS Medicare.
“Remember, the LPN’s not billing,” said CMS’s William Rogers, MD, reminding the caller that the visit would be billed under the physician’s NPI as “incident to.” But the caller still considered it “odd” that an LPN could perform an AWV, since it’s similar to an E/M service.
“It’s a different sort of service – there’s not really any clinical judgment involved,” Rogers said. “It’s a service which includes a lot of sort of administrative steps, verifying that people have certain preventive services done and things like that, and so it is intended to be a collaborative service.”
Keep in mind that CMS does not have a national policy allowing LPNs and RNs to perform AWVs, but reps from the agency confirmed that it’s within the rights of the individual MACs to make this determination.
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