Physician Assistant (PA) Billing and Payment Updates

Prior to January 1, 2022, payment for the Physician Assistant’s (PA’s) services could only be made to the PA’s employer, not to the PA himself/herself. That is, the PA could not individually enroll in Medicare to receive direct payment for his or her services. This also meant that the PA could not reassign his or her benefits to the employer. Prior to January 1, 2022, the PA’s NPI was used for identification purposes only when billing for PA services, because only an appropriate PA employer or, a provider/supplier for whom the PA furnished services as an independent contractor, could bill for PA services.

Now, there have been changes.

Pursuant to the CY 2022 Physician Fee Schedule Final Rule, a PA may now: 

• Individually enroll in Medicare (e.g., as a sole proprietorship, professional corporation) 
• Receive direct payment for his/her services 
• Establish PA groups (e.g., LLCs) 
• Reassign his/her benefits to his/her employer 

The previous requirement that the PA’s employer must bill for his/her services has been eliminated.
Effective January 1, 2022, direct billing and payment for PA services may be made to the PA. Also, effective January 1, 2022, PAs must have their own “nonphysician practitioner” national provider identification (NPI) number for billing purposes. Specialty code 97 applies for PAs enrolled in Medicare.

Assignment for PA services is mandatory. All claims for PA services must be made on an assignment basis. If any person or entity (PA employer or, a provider/supplier for whom the PA furnishes services as an independent contractor) knowingly and willfully bills the beneficiary an amount in excess of the appropriate coinsurance and deductible, the responsible party is subject to a civil monetary penalty not to exceed $2,000 for each such bill or request for payment.

Resources 
CMS outlines the enrollment, benefit, and payment guidelines for Physician Assistant (PA) services in the following IOM resources:

• IOM 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 190 Physician Assistant (PA) Services  (PDF)
• IOM 100-04, Medicare Claims Processing Manual, Chapter 12, Section 110 Physician Assistant (PA) Services Payment Methodology (PDF)
• IOM 100-08, Medicare Program Integrity Manual, Chapter 10, Section 10.2.3.12 – Physician Assistants (PDF)