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Incident-to billing can be confusing. Unfortunately, many NPs find their employers want to bill under incident-to, yet there is often a mis-understanding of this issue, as we’ve talked about before. The problem is it can potentially result in fraud charges if the rules are not followed.
Define (as per CMS): “Incident to” services are defined as those services that are furnished incident to physician professional services in the physician’s office (whether located in a separate office suite or within an institution) or in a patient’s home. These services are billed as Part B services to your carrier as if you personally provided them, and are paid under the physician fee schedule.
Allowable Discount: 15% to NPs and PAs. For example, if MD is allowed $100, NPs/PAs are allowed $85.
First of all the visit takes place in the office.
The physician must perform the initial service and continue to be actively involved in the course of treatment.
The NP or PA sees the patient in follow-up for the identified problem and follows the plan of care.
The physician MUST be in the office suite at the time the visit takes place, not necessarily in the exam room, but in the office incase “direct” supervision is required.
The documentation needs to reflect the essential requirements for an incident to services.
The NP or PA must be an employee or what medicare refers to as a “leased employee” or an “independent contractor” that is paid for by the physician and practice.
What’s your experience with incident-to billing?