Light box treatment billing; PA supervision of nurses; nurses and light treatments

I have been reviewing our light box treatment billing and am concerned about what this dermatology practice has been billing versus what the service actually entails. I have read the CPT definitions and think they are billing it incorrectly. Can you clarify that my thinking is correct before I approach the group?

Specifically, I am writing with respect to CPT code 96910. Per CPT the definition reads:

In our office, the patient only gets the UVB light exposure. We do not apply any coal tar or petrolatum; nor does the patient. Based on this, I feel that billing CPT code 96910 is inappropriate and that code 96900 should be billed instead. Is this correct? I realize that there is a significant difference in reimbursement and that changing to CPT code 96900 will reduce our profits considerably, but I believe that the continued use of this code is unacceptable. Your thoughts?
Knee Deep

A. Dear Knee Deep: You are correct. The definition is very clear. It requires a mixture of UVB exposure and the application of tar or UVB exposure and the application of petrolatum. If only the UVB light exposure is delivered, then the use of CPT code 96910 is inappropriate.

Similarly, if the practice bills CPT code 96912, the patient must take psoralens prior to exposure to the UVA light. If psoralens isn't prescribed, then CPT code 96912 should not be used.

In both cases, if only light exposure is provided, the use of CPT code 96900 would be the only acceptable way to bill.

Q. Our group has three doctors and two physician assistants (PAs). We offer all types of photodynamic therapy as well as traditional light therapies for a variety of skin conditions. We have a question that involves our PAs. We are aware that a provider must be on the premises when a patient receives any type of light therapy, even if a nurse in our employ actually takes care of the entire patient encounter, including bringing the patient to the room, setting the machine, putting the patient (or parts of the body, when appropriate) into the machine, and performing pre- and post-treatment assessments. If none of the physicians is on site, but only one of the PAs is available to supervise the nurses involved in the light treatments, does this meet the definition of incident? If so, under whose name is the service billed?
Enlightened

A Dear Enlightened: I can't give you a definitive "yes" or "no" answer, but I can offer the following input:

1. Check for any state restrictions imposed by the entity that licenses PAs in your state. Some states limit the services that a PA can perform under their licensure.

2. Check with your contracted carriers to whom you are going to bill these services for any restrictions. Some do not recognize PAs. Some do not credential PAs. Some do. Others may require the presence of a physician at all times when the PA is providing services, in which case you can't have someone who requires supervision supervising someone else who is required to be supervised.

3. If there are no restrictions to either numbers one and two, then the PA can supervise the nurses as long as the PA bills for the light therapies under his or her own name and provider number, not the name and number of any of the providers in the practice. PAs can supervise ancillary staff if no state or contractual limitations exist.

Note: If you contact the contracted carriers and inquire regarding their policy regarding PAs supervising staff, always get their advice in writing. Don't move forward based solely on information obtained over the telephone.