Clarifying incident-to billing

Q:Incident-to billing is confusing and our practice is unclear on how and when it should be used appropriately. What guidance can you provide?

A: First, I think we need to remember some of the basic incident-to requirements. According to the Centers for Medicare and Medicaid Services (CMS) MLN Matters No. SE0441, for services performed in the office, qualifying “incident-to” services must be provided by a caregiver whom the physician directly supervises, and who represents a direct financial expense to the physician (such as a “W-2” or leased employee, or an independent contractor).

To qualify as “incident to,” services must be part of your patient’s normal course of treatment, during which a physician personally performed an initial service and remains actively involved in the course of treatment. The physician does not have to be physically present in the patient’s treatment room while these services are provided, but he or she must provide direct supervision , meaning the physician must be present in the office suite to render assistance, if necessary.

If you are a solo practitioner, you must directly supervise the care. If you are in a group, any physician member of the group may be present in the office to supervise.

 

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