Many allergists are assisted by nurse practitioners (NPs) and/or physician assistants (PAs) in providing care in the office. The Advocacy Council frequently receives questions as to whether mid-level practitioners can provide allergy skin testing. We have also heard of at least one instance in which a private payer has questioned whether mid-level practitioners may provide this service and have asked for evidence of specialty certification in allergy.
The scope of practice for NPs and PAs is determined by state licensing boards. Because of the differences in training, some states allow NPs to work independently but nearly all states require PAs to work under the supervision of a physician. There is no national specialty certification in allergy for NPs or PAs. Most train on the job by working with an allergist. Medicare permits NPs and PAs to perform allergy skin testing if it is within their scope of practice under state law. The new Medicare rules for 2021 allow NPs and PAs to also supervise the performance of diagnostic tests, including skin testing, that are performed by other clinical staff if permitted by state law.
What does all of this mean for your practice? If you have NPs or PAs in your practice whom you have trained to perform skin testing, they can do so unless prohibited by the state scope of practice laws. The level of supervision also depends on state law. In some states NPs can work independently without physician supervision. Other states require some level of supervision or a collaborative relationship with a physician. PAs must generally work under a physician’s supervision, although the level of supervision may vary by state. The best source of information on scope of practice would be the state licensing boards that regulate NPs and PAs.
Remember – if NPs or PAs perform or supervise skin testing, the services should be billed under the NP’s or PA’s NPI number. Medicare pays 85% of the physician payment for services provided by NPs and PAs. The “incident to” billing rules do not apply to diagnostic tests.
We’ll continue to monitor this issue and report on any changes. The Advocacy Council – we have you covered!