Title: Billing Basics For ‘Incident-To’ Services
1 Billing Basics For Incident-To Services
2Billing Basics For Incident-To Services
- Defining Incident to
- Incident-to services are usually initiated by a
physician and provided by a non-physician
provider (NPP) following the care plan and
supervision of the physician. The physician must
be physically present in the office suite and the
services provided must be commonly performed in
the physicians office. If the criteria are met,
the service should be billed under the
physicians national provider number (NPI) and
the practice receives 100 percent of the
physicians fee schedule for the service. Note
that, incident-to services are only applicable to
Medicare. Incident-to services are only
applicable for charges billed to a Medicare
contractor. You will have to verify with each
private insurance carrier on how to bill for
services performed by an NPP. - Billing Requirements for Incident-to Services
- As discussed above, incident-to billing applies
only to Medicare and, the incident-to billing
does not apply to services with their own benefit
category. Diagnostic tests, for example, are
subject to their own coverage requirements. - The service billed incident to must take place in
a noninstitutional setting, which the Centers
for Medicare Medicaid Services (CMS) defines as
all settings other than a hospital or skilled
nursing facility. Hospital services incident to
physicians or other practitioners services
rendered to outpatients (including drugs and
biologicals which are not usually
self-administered by the patient), and partial
hospitalization services incident to such
services may also be covered.
3Billing Basics For Incident-To Services
- Incident to services cannot be rendered on the
patients first visit, or if a change to the plan
of care occurs. A Medicare-credentialed physician
must initiate the patients care. If the patient
has a new or worsened complaint, a physician must
conduct an initial evaluation and management
(E/M) service for that complaint and must
establish the diagnosis and plan of care. - Subsequent to the encounter during which the
physician establishes at a diagnosis and
initiates the plan of care, an NPP may provide
follow-up care under the direct supervision of
a qualified provider. - A physician must actively participate in and
manage the patients course of treatment. This
requirement typically is defined by individual
state licensure rules for physician supervision
of NPPs. - Both the credentialed physician and the qualified
NPP providing the incident to service must be
employed by the group entity billing for the
service. If the physician is a sole practitioner,
the physician must employ the NPP. - The incident to service must be of a type usually
performed in the office setting and must be part
of the normal course of treatment of a diagnosis
or illness. - Billing Basics for Incident-to Services
- Eligible NPP An NPP is a non-physician provider
who must meet supervision requirements in order
to provide incident to services and to receive
appropriate compensation for the physician. NPPS
can be a physician assistant (PA), nurse
practitioner (NP), clinical nurse specialist
(CNS), or advanced practice registered nurse
(APRN), etc., and their scope of practice as
defined under state law must allow providing
incident to services
4Billing Basics For Incident-To Services
- New patient A patient new to the office would
not have been seen by the physician, and
consequently there wouldnt be a
physician-initiated plan of care. The patient
would not be under the physicians supervision.
So, if the NPP evaluates and treats the new
patient without an initial visit with the
physician, then he or she will have to bill the
services under their NPI number and receive
reimbursement at 85 percent of the physician fee
schedule. - Established Patient The NPP would not be able to
bill established patient, this as incident-to.
The new complaint would not be in the physicians
plan of care and so it would not meet the
criteria for being billable as an incident to
service. The NPP could address the patients new
problem but they would need to bill under their
own NPI and receive 85 percent of the physicians
fee schedule rate. - Direct supervision means the physician must be in
the office suite and can immediately be available
to provide assistance if needed. - Shared/split visit A shared/split visit is when
both the physician and the NPP share a visit in
treating the patient. This is now allowed for
outpatient services such as office visits. Both
the physician and NPP must independently document
their part of the visit. For example, an
established patient presents with a new problem
along with an established problem and is being
seen by the NPP. The NPP can call in the
physician to assess the new problem but the
documentation must include the NPPs assessment
of the established problem, and the physician
must document the assessment of the new problem
separately.
5Billing Basics For Incident-To Services
Accurate billing and coding backup by proper
documentation will reimburse all your
Incident-to services. Most of the time,
practice owners are unaware of different billing
scenarios in Incident-to services and end up
receiving claim denials. Medisys Data Solutions
can assist you in medical billing for your
rheumatology practice including Incident-to
services. Our expert medical billers and coders
are well versed with billing guidelines and
billing scenarios and ensure accurate insurance
reimbursements for delivered services. To know
more about our rheumatology billing and coding
services, contact us at info_at_medisysdata.com /
302-261-9187
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