​COVID-19 (Coronavirus): CRNP and PA direct supervision requirements

May 14, 2020

This article was revised on May 14, 2020, to update the effective timeline.

Independence is committed to providing our members with access to the care they need. As COVID-19 has escalated into a pandemic, we are working to make sure that our members can receive appropriate testing and treatment for the virus causing COVID-19 if needed.

We encourage all Independence members to visit our dedicated COVID-19 webpage regularly for the latest news and updates. We will continue to evaluate member needs as the situation changes.

Temporary “direct supervision” definition change

Effective March 6, 2020, through June 30, 2020, Independence’s definition of “direct supervision” of a Certified Registered Nurse Practitioner (CRNP) or Physician Assistant (PA) in accordance with the applicable policy identified below has been modified to include direct supervision by a physician’s virtual presence. This temporary change is subject to re-evaluation during the public health emergency.

Virtual presence includes audio/video real-time communications technology when used to reduce exposure risks for the member or health care provider.

All other criteria for services to be recognized as “Incident to” must be met, and include:

  • the individual seeking treatment must be an established patient, and the service must be treatment for an existing problem;
  • the treatment course must have been initiated by a physician at a previous encounter;
  • the service must be an integral part of the patient’s course of treatment;
  • the physician must remain involved in the treatment plan;
  • the service must be of a type commonly furnished in a physician’s office or clinic (not in an institutional setting);
  • the service must be an expense to the physician’s practice.

The patient’s medical record must reflect the medical necessity for the care provided. These medical records may include but are not limited to: records from the professional provider’s office, hospital, nursing home, home health agencies, therapies, and test reports.

Billing and coding

The supervising physician should bill “Incident to” services performed by a CRNP or PA using their own National Provider Identifier (NPI) and report Modifier SA, Nurse practitioner rendering service in collaboration with a physician.


The policies affected by this change include:

Learn more

For more information about Independence’s position on COVID-19, please review the following resources: