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

December 2, 2020

This article was revised on December 2, 2020, to update the effective timeline.

Independence is committed to providing our members with access to the care they need during the COVID-19 pandemic. We encourage all Independence members and providers 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

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. The change is effective:

  • Commercial members: March 6, 2020, through March 31, 2021, and is subject to re-evaluation during the public health emergency;
  • Medicare Advantage members: March 6, 2020, and for the duration of 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: