What is a Non-Physician Practitioner (NPP)?
A Non-Physician Practitioner (NPP) is a licensed healthcare provider who is not a physician but is authorized to deliver medical services within a defined scope of practice. The term is commonly used in CMS documentation and Medicare billing guidance to categorize advanced practice clinicians who can diagnose, treat, and manage patient care either independently or under supervision.
NPPs play a foundational role in care management programs such as Chronic Care Management (CCM), Principal Care Management (PCM), and Behavioral Health Integration (BHI). They often serve as the supervising or billing provider in these models and are frequently recognized as Qualified Health Professionals (QHPs) for the purposes of Medicare compliance.
While the exact definition of an NPP can vary slightly between federal programs and commercial payers, it typically includes Nurse Practitioners (NPs), Physician Assistants (PAs), Certified Nurse Midwives (CNMs), Clinical Nurse Specialists (CNSs), and some licensed behavioral health providers.
Key Components of a Non-Physician Practitioner
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Holds a valid clinical license or credential issued by a U.S. state board
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Authorized to deliver services within a defined scope of practice
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Commonly includes NPs, PAs, CNSs, CNMs, and licensed clinical psychologists
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May qualify as a QHP under CMS billing rules, depending on the program
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Often supervises care teams in CCM, PCM, or CoCM models
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Can bill Medicare or other payers directly if enrolled and credentialed
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Subject to documentation, supervision, or attestation requirements depending on program and payer
The Role of a NPP in Care Delivery
Non-Physician Practitioners are critical contributors to modern care teams, especially in outpatient and value-based care environments. Depending on the program and payer, NPPs may operate independently or under physician supervision — but in either case, they are typically responsible for ensuring that clinical services meet medical necessity and billing compliance standards.
In many care models, NPPs function as the credentialed provider who either:
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Directly delivers the service,
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Supervises clinical staff (such as RNs or care coordinators),
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Or attests to the time and documentation needed for CMS billing purposes.
Examples of typical responsibilities for NPPs include:
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Conducting patient assessments and contributing to care plan development
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Reviewing documentation for Chronic Care Management (CCM) or Principal Care Management (PCM)
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Supervising staff in Transitional Care Management (TCM) or Behavioral Health Integration (CoCM) models
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Signing off on time-based billing attestations
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Participating in compliance audits and quality reporting initiatives
Billing and Reimbursement Compliance with NPPs
Non-Physician Practitioners play a key role in determining whether a service is billable under CMS care management programs. Depending on the program and payer, NPPs may either bill directly or act as supervising providers for services delivered by other care team members.
In Medicare and many commercial insurance models, NPPs are recognized as Qualified Health Professionals (QHPs) — meaning they are permitted to:
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Supervise time-based or incident-to services
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Sign off on care plans and progress notes
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Attest to time spent on Chronic Care Management (CCM), Principal Care Management (PCM), or Transitional Care Management (TCM)
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Serve as the billing provider for CoCM codes (99492–99494), when applicable
When NPP Status Matters
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To bill for CCM or PCM, the NPP must be the supervising provider and complete required documentation
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In CoCM programs, the NPP may serve as the billing clinician while collaborating with behavioral health managers
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For Transitional Care Management (TCM), NPPs may coordinate care post-discharge and fulfill communication requirements
Billing eligibility varies by payer, and credentialing requirements — such as Medicare enrollment and scope of supervision — must be met for reimbursement.
Programs that Typically Involve Non-Physician Practitioners
Non-Physician Practitioners are frequently used as billing providers or supervising clinicians in CMS-defined care management programs. While requirements vary by payer, the following programs often rely on NPPs for documentation, compliance, and supervision of time-based or collaborative services.
In each program, the NPP must meet all credentialing and documentation requirements in order to serve as the billing or supervising clinician. Specific guidelines may vary by payer and care setting.
Frequently Asked Questions about QHPs
1. What is a Non-Physician Practitioner (NPP)?
A Non-Physician Practitioner is a licensed healthcare provider who is not a physician but is authorized to deliver medical services within their scope of practice. NPPs include Nurse Practitioners, Physician Assistants, Certified Nurse Midwives, and Clinical Nurse Specialists, among others.
2. How is an NPP different from a Qualified Health Professional (QHP)?
NPP is a broader role category. Many NPPs qualify as QHPs under CMS billing definitions, but not all QHPs are considered NPPs. Eligibility depends on the specific program and the provider’s credentials.
3. Can NPPs bill Medicare directly?
Yes. NPPs such as NPs and PAs can bill Medicare directly if they are credentialed, enrolled, and providing services within their approved scope of practice.
4. Do NPPs supervise other care team members?
Often, yes. In care management programs like CCM, PCM, and CoCM, NPPs frequently serve as supervising clinicians for RNs, care coordinators, or behavioral health managers.
5. Are behavioral health providers considered NPPs?
Some are. Licensed Clinical Psychologists are generally recognized as NPPs by CMS. Other roles like LCSWs or counselors may be eligible depending on the program and payer rules.