How to Do Incident-To Billing Right and Avoid Costly Mistakes

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How to Do Incident-To Billing Right and Avoid Costly Mistakes

Navigating incident-to billing can feel overwhelming, but understanding it is essential for maximizing reimbursements and avoiding costly audits. This Medicare billing approach lets you receive 100% of the physician fee schedule—but only if done right. Ready to master incident-to billing like a pro? Let’s dive in.

Key Takeaways:

  • Incident-to billing allows practices to bill Medicare at 100% of the physician fee schedule.
  • A physician must create an initial care plan and provide direct supervision during follow-ups.
  • Rules vary by state and payer, so check your contracts and laws before billing.
  • Common pitfalls include billing for new problems and misunderstanding supervision requirements.
  • Proper documentation is crucial to avoid audits and ensure compliance.

What Is Incident To Billing (and Why Should You Care)?

At its core, incident-to billing refers to services or supplies performed as an integral but incidental part of professional services provided by a doctor during the diagnosis or treatment of an illness or injury. Translation? You’re billing for services in which the doctor has played a key role—either directly or through setting up the care plan.

The benefit? Incident-to billing allows reimbursement at 100% of the physician’s fee schedule. Without it, services provided by physician assistants (PAs) or nurse practitioners (NPs) are reimbursed at only 85%. That’s a big difference for your bottom line!

But—and this is a huge but—Medicare and other payers have strict requirements for when and how you can bill incident to. Mess it up, and you risk audits, clawbacks, and major headaches.


Incident-To Billing Guidelines: How to Qualify

✅ 1. The Physician Must See the Patient First

  • The physician must conduct the initial visit and create a treatment plan.
  • The NPP can provide follow-up care—but cannot diagnose or treat new conditions.

🔹 Example:
✔ A physician sees a patient for hypertension and prescribes medication.
✔ The NP follows up to monitor blood pressure and adjust medication as needed.
This qualifies for incident-to billing.

❌ If the patient develops a new condition, the physician must evaluate it first before the NPP can treat it under incident-to.


✅ 2. The NPP Must Follow the Physician’s Treatment Plan

  • The NPP can only provide services outlined in the physician’s care plan.
  • New diagnoses or treatment plans require physician involvement.

🔹 Example:
✔ A PA follows up with a patient’s diabetes management using the physician’s care plan.
✔ The patient complains of new knee pain.
❌ The PA cannot diagnose or treat the new knee pain under incident-to.
✅ The physician must see the patient first before the PA can continue care for the knee pain.


✅ 3. The Physician Must Be On-Site During the Visit

  • The physician must be physically present in the office suite while the NPP provides care.
  • The physician does not have to be in the exam room, but they must be available for immediate assistance.

🔹 Example:
✔ A PA sees a patient for a follow-up asthma visit.
✔ The physician is in the office and available if needed.
This qualifies for incident-to billing.

🚫 If the physician is off-site, incident-to billing is NOT allowed—the NPP must bill under their own NPI at 85% of the fee schedule.


✅ 4. Incident-To Does NOT Apply in Hospitals or Facilities

  • Incident-to only applies in an office setting (e.g., physician offices or private practices).
  • It cannot be used in hospitals, emergency rooms, or skilled nursing facilities (SNFs).

🔹 Example:
❌ A PA sees a patient in a hospital outpatient clinic.
🚫 This cannot be billed as incident-to—it must be billed under the PA’s NPI.

✅ If the same visit occurred in a physician’s office, incident-to billing could be used (as long as other requirements are met).


✅ 5. The Physician Must Remain Involved in the Patient’s Care

  • The physician must continue to be actively involved in the patient’s treatment.
  • Medicare requires “direct supervision”—meaning the physician must be in the office suite during visits.

🚨 If a physician leaves the practice, the NPP can no longer bill incident-to for that physician’s patients.


Rules of Incident To Billing

Rule #1: Know Your Payer Requirements for Incident To Billing

Before you even consider using incident to billing, you need to know your payer’s rules. Medicare sets the gold standard for incident-to billing guidelines, but commercial payers often tweak these rules. That means it’s critical to check with:

  • Your provider relations team
  • Insurance contracts
  • Your state’s laws

Remember, what works for Medicare might not fly with a commercial insurer. And state laws regarding supervision of PAs and NPs can vary widely, which also impacts your ability to bill incident to.


Rule #2: The Doctor Must Have Face-to-Face Contact First

Here’s where many practices go wrong: To use incident-to billing, the physician must conduct the initial face-to-face encounter with the patient and establish a care plan. This isn’t optional—it’s a dealbreaker.

So, what does this mean in practice?

  • The doctor sees the patient first, develops a treatment plan, and documents it.
  • Auxiliary personnel (like a PA or NP) can follow that care plan for subsequent visits.

If a PA or NP sees a patient for something outside of the established care plan, incident-to billing cannot be used.


Rule #3: The Doctor Must Provide Direct Supervision

Another major requirement for incident-to billing is direct supervision. Here’s what that looks like:

  • The doctor must be physically present in the office suite while the PA or NP sees the patient.
  • They don’t need to be in the same room but must be available if needed.

This is Medicare’s definition, and it applies to most situations. If the supervising physician isn’t on-site, incident-to billing is off the table.

Pro tip: There are also situations where general supervision may apply, but this is more common for chronic care management patients. Make sure you know when each type of supervision is allowed.


Why State Laws Matter for Incident-To Billing

Here’s where things get even trickier: State laws. Across the U.S., the requirements for supervising PAs and NPs vary. For example:

  • Some states require NPs to be supervised by a physician.
  • Other states allow NPs to operate and practice independently.

So, if you’re in a state where NPs can work independently, you may not even be able to use incident-to billing for their services.

See why it’s so important to double-check your state’s laws and payer contracts?


Common Scenarios for Incident-To Billing

Incident-to billing is more commonly used in specialty practices (think oncology, cardiology) than in primary care. Here’s why:

  • The doctor often sets up a complex care plan during the initial visit in specialties.
  • PAs or NPs then follow that care plan during follow-up visits.

For example:

ScenarioCan You Bill Incident To?
Initial visit with doctorNo, because the doctor is providing the service.
Follow-up visits with PAYes, if the PA is following the care plan and the doctor is on-site.
New condition addressed by PANo, because it’s outside the original care plan.

Primary care providers may use incident-to billing as well, but it’s typically less common. The rules for supervision, care plans, and payer guidelines are just as strict in these settings.


Correct Incident-To Billing Examples

✅ Example 1: Follow-Up Visit for an Existing Condition

🔹 Scenario:

  • A physician initially diagnoses a patient with Type 2 diabetes and prescribes metformin.
  • On a follow-up visit, an NP adjusts the dosage based on lab results while the physician is present in the office suite.
  • The NP documents the visit and follows the original care plan established by the physician.

Why This Qualifies for Incident-To Billing:
✔ The physician initially saw the patient and created the treatment plan.
✔ The NP is providing follow-up care—not diagnosing a new condition.
✔ The physician is in the office suite at the time of the visit.

👉 The NP can bill under the physician’s NPI at 100% of the Medicare rate.


✅ Example 2: Hypertension Management in a Medical Practice

🔹 Scenario:

  • A patient is diagnosed with hypertension by the physician and started on lisinopril.
  • The patient returns for a blood pressure check and medication adjustment.
  • A PA sees the patient and increases the lisinopril dosage based on the physician’s original care plan.
  • The physician is on-site and available if needed.

Why This Qualifies for Incident-To Billing:
✔ The physician originally saw the patient for this condition.
✔ The PA is following the established treatment plan.
✔ The physician is physically in the office suite.

👉 The service can be billed under the physician’s NPI at 100% reimbursement.


Incorrect Incident-To Billing Examples

❌ Example 3: New Condition Diagnosed by an NP

🔹 Scenario:

  • A patient comes in for knee pain and is seen directly by an NP.
  • The NP orders imaging and prescribes NSAIDs, without the physician evaluating the condition.
  • The physician is in the office, but they never personally saw the patient for this issue before.

Why This Does NOT Qualify for Incident-To Billing:
🚫 The physician never saw the patient for this condition.
🚫 The NP is diagnosing a new problem without physician involvement.

👉 This must be billed under the NP’s NPI at 85% of the Medicare fee schedule.


❌ Example 4: Physician Not Present in the Office

🔹 Scenario:

  • A physician starts a treatment plan for asthma.
  • A PA sees the patient for a follow-up visit and provides medication adjustments.
  • However, the physician is out of the office during this visit.

Why This Does NOT Qualify for Incident-To Billing:
🚫 The supervising physician is NOT physically present in the office suite.
🚫 Even though this is a follow-up visit, it must be billed under the PA’s NPI at 85% reimbursement.

👉 You cannot bill incident-to if the physician is not on-site.


❌ Example 5: Medical Assistant or RN Performing the Service

🔹 Scenario:

  • A registered nurse (RN) provides wound care to a patient following a physician’s plan of care.
  • The RN wants to bill incident-to under the physician’s NPI.

Why This Does NOT Qualify for Incident-To Billing:
🚫 RNs and Medical Assistants (MAs) are NOT eligible for incident-to billing.
🚫 Only NPs, PAs, CNSs, and CNMs can bill incident-to.

👉 This must be billed under the physician’s NPI as a direct service—or under the RN’s scope if applicable.


Medicare’s Incident-To Billing Guidelines

To bill incident-to correctly, all of these rules must be met:

✅ 1. The Physician Must First See the Patient

  • The physician must establish the patient’s diagnosis and treatment plan.
  • The NPP can then provide follow-up care—but cannot diagnose new conditions.

🔹 Example:
✔ A physician sees a patient for hypertension and prescribes medication.
✔ A PA sees the patient for a follow-up blood pressure check.
✔ The PA follows the physician’s treatment plan and adjusts the dosage.

This qualifies for incident-to billing.


✅ 2. The NPP Must Follow the Physician’s Plan of Care

  • The NPP can adjust medications, order tests, and provide treatment—but only if it aligns with the physician’s plan.
  • If the patient develops a new condition, the physician must see them first before the NPP can continue care under incident-to.

🔹 Example:
✔ An NP is managing a patient’s diabetes based on the physician’s treatment plan.
✔ The patient complains of new back pain.
✔ The NP cannot diagnose the new condition under incident-to billing.

❌ The physician must evaluate the new condition first—or the NP must bill under their own NPI at 85% of the fee schedule.


✅ 3. The Physician Must Be On-Site During the Visit

  • The physician must be physically present in the office suite while the NPP provides care.
  • The physician does not have to be in the exam room—but must be available for immediate assistance.

🔹 Example:
✔ A PA performs a follow-up visit for a patient with asthma.
✔ The physician is in the office and available if needed.

This qualifies for incident-to billing.

🚫 If the physician is off-site, you must bill under the NPP’s NPI at 85% reimbursement.


✅ 4. Incident-To Does Not Apply in Hospitals or Facilities

  • Incident-to billing is only allowed in office settings (e.g., physician offices or private practices).
  • It cannot be used in hospitals, emergency rooms, or skilled nursing facilities.

🚫 Example:

  • A PA sees a patient in a hospital outpatient department for a follow-up visit.
  • The service cannot be billed as incident-to—it must be billed under the PA’s NPI.

✅ 5. Only Certain Providers Can Bill Incident-To

🚫 Medical Assistants (MAs) and Registered Nurses (RNs) cannot bill incident-to.
🚫 Only NPs, PAs, CNSs, and CNMs qualify.

🔹 Example:
❌ An RN administers a flu shot under physician supervision.
❌ The physician wants to bill incident-to.

🚫 This does NOT qualify for incident-to billing.
👉 Flu shots and injections have separate Medicare billing rules.


Why Is Incident-To Billing Documentation So Important?

Proves Compliance – Medicare audits incident-to claims to ensure services meet regulations.
Ensures Full Reimbursement – Proper documentation supports billing at 100% of the Medicare Physician Fee Schedule (MPFS).
Prevents Recoupments & Penalties – Missing documentation can trigger claim denials or overpayment demands.


Key Incident-To Billing Documentation Requirements

To bill incident-to services under a physician’s NPI, your documentation must include the following elements:

✅ 1. Proof That the Physician Performed the Initial Visit

  • The physician must personally evaluate the patient and create the treatment plan.
  • The NPP (nurse practitioner, physician assistant, etc.) cannot diagnose or treat a new condition under incident-to billing.

🔹 Example Documentation:
“Patient seen by Dr. Smith on 1/10/24 for newly diagnosed hypertension. Initial treatment plan established, including lifestyle changes and lisinopril 10mg daily.”

🚫 Missing Documentation Example:
“Patient follows up for hypertension today.”
🚨 (No mention of the physician’s initial visit!)


✅ 2. Statement That the NPP Followed the Physician’s Plan of Care

  • The NPP must stick to the physician’s established treatment plan.
  • If a patient has new symptoms, the physician must see them before the NPP continues care under incident-to billing.

🔹 Example Documentation:
“Patient seen for follow-up on hypertension. Treatment plan established by Dr. Smith on 1/10/24. BP controlled, no medication changes.”

🚫 Missing Documentation Example:
“Patient seen for follow-up. BP checked, meds adjusted.”
🚨 (No reference to the supervising physician’s treatment plan!)


✅ 3. Documentation of Physician’s On-Site Presence

  • The physician must be physically present in the office suite when the NPP provides services.
  • The physician does not need to be in the exam room, but they must be available for immediate assistance.

🔹 Example Documentation:
“Dr. Smith on-site during today’s visit, supervising incident-to services.”

🚫 Missing Documentation Example:
“Patient seen by NP today.”
🚨 (Does not confirm physician presence!)


✅ 4. Physician Oversight & Active Participation in Care

  • The physician must remain involved in the patient’s ongoing treatment.
  • Medicare expects the physician to periodically review the patient’s progress and adjust the care plan as needed.

🔹 Example Documentation:
“Dr. Smith reviewed today’s visit note and concurs with the treatment plan.”

🚫 Missing Documentation Example:
“Follow-up visit completed.”
🚨 (No mention of physician oversight!)


✅ 5. Clear Identification of the Supervising Physician

  • The medical record must specify the physician responsible for supervising incident-to services.
  • This is especially important in group practices, where multiple physicians work together.

🔹 Example Documentation:
“Supervising physician: Dr. Smith. Incident-to services provided by NP Jones under Dr. Smith’s supervision.”

🚫 Missing Documentation Example:
“Seen by NP today.”
🚨 (No supervising physician identified!)


✅ 6. Proper Use of CPT Codes & Modifier Guidelines

  • Incident-to services must be billed under the physician’s NPI, using the appropriate CPT codes.
  • Some payers require additional modifiers (e.g., SA modifier for some commercial plans).

🔹 Example Documentation:

  • CPT Code: 99213
  • Billing NPI: Physician’s NPI (not the NPP’s)
  • Modifier (if required by payer): SA (for certain commercial insurers)

🚫 Missing Documentation Example:

  • CPT Code: 99213
  • Billing NPI: NPP’s NPI
    🚨 (Results in 85% reimbursement instead of 100%!)

Mastering Incident To-Billing—Avoiding Pitfalls and Maximizing Reimbursement

Alright, let’s keep this incident-to billing train rolling! By now, you’ve got a solid grasp of the basics—payer requirements, the face-to-face rule, direct supervision, and state-specific laws. But there’s still a lot to unpack to make sure you’re squeezing every penny out of this billing method without falling into any traps.

Let’s dive into common pitfalls, real-world examples, and some juicy details on reimbursement strategies to make sure you’re doing it right.


Pitfall #1: Billing Incident-To for New Problems

One of the most common mistakes practices make with incident-to billing is trying to bill it for new or unrelated conditions. Let me be super clear here: incident-to billing is only allowed for services tied to the original care plan created by the doctor.

For example:

  • ✅ Correct: A PA sees a patient for diabetes management, following the care plan the physician initially developed.
  • ❌ Incorrect: A PA treats that same patient for a new rash or other unrelated issue.

When a patient presents with a new condition, the PA or NP’s services must be billed under their own National Provider Identifier (NPI), reimbursed at 85% of the physician fee schedule.

This is why detailed documentation is critical. You’ll need to clearly show that the services provided by the auxiliary personnel are part of the ongoing care plan and not a deviation.


Pitfall #2: Misunderstanding Supervision Requirements

Let’s revisit the direct supervision rule because this is another area where practices can slip up.

For Medicare, direct supervision means the physician must be in the same office suite—not the same room. That sounds simple, but here’s where people mess it up:

  • The physician steps out: If the doctor is out at lunch, running errands, or attending a meeting outside the office, you cannot bill incident to.
  • Remote offices: If your practice has multiple office locations and the supervising physician isn’t physically present in the same location as the auxiliary staff, you cannot bill incident to.

This rule also applies to telehealth visits. If the physician isn’t physically on-site during the telehealth service, incident-to billing doesn’t apply.


Reimbursement Strategies: Why Incident-To Can Be a Game-Changer

So, why all the fuss about incident to billing? Simple: Money.

When billed correctly, incident-to billing allows you to receive 100% of the Medicare Physician Fee Schedule for services performed by auxiliary personnel. Without it, services provided by PAs or NPs are reimbursed at 85% of the fee schedule.

Let’s crunch some quick numbers:

ServiceBilled Under PhysicianBilled Under PA/NP
Office Visit (Level 3)$100$85
Office Visit (Level 4)$150$127.50

If your practice provides dozens (or hundreds) of these services per month, that 15% gap adds up fast. This is why it’s worth taking the time to understand and implement incident-to billing properly.


Real-World Example: How Specialty Practices Use Incident-To Billing

Let’s talk about how incident-to billing plays out in the real world, especially in specialty practices.

Oncology Example:

  • A patient has an initial consultation with the oncologist, who creates a treatment plan for chemotherapy.
  • On subsequent visits, a PA sees the patient to monitor their response to treatment, manage symptoms, and ensure adherence to the plan.
  • Since the PA is following the oncologist’s care plan and the oncologist is in the building, incident-to billing applies.

Primary Care Example:

  • A family physician evaluates a patient with hypertension and creates a management plan.
  • During follow-up visits, a nurse practitioner monitors the patient’s blood pressure, adjusts medication as planned, and reports to the physician.
  • As long as the physician is in the office suite, the visits can be billed incident-to.

The Documentation Dilemma: Cover Your Tracks!

Here’s the golden rule for incident-to billing: If it’s not documented, it didn’t happen.

Medicare auditors are notorious for combining documentation to ensure compliance. To protect your practice, make sure you:

  1. Clearly Document the Care Plan: The physician’s care plan must be outlined in the chart, with specific details on how auxiliary personnel should proceed.
  2. Note Physician Supervision: Include documentation that the supervising physician was on-site during the visit.
  3. Distinguish New vs. Ongoing Conditions: Clearly indicate when a service is part of the ongoing care plan versus a new problem.

Pro tip: Have regular internal audits to ensure your documentation is airtight. It’s better to catch mistakes internally than during a Medicare audit.


Why Commercial Payers Matter

While Medicare is the go-to reference for incident-to billing, many commercial payers follow similar rules. However, there are some key differences you need to be aware of:

  • Reimbursement Rates: Some commercial payers may reimburse differently for services performed by PAs/NPs.
  • Supervision Rules: A few payers might allow more flexibility with supervision requirements.
  • Contract-Specific Guidelines: Always check your payer contracts to ensure compliance.

How to Set Up an Incident To-Billing Workflow and Maximize Your Reimbursement

Now that you’ve mastered the theory behind incident-to billing, let’s talk action steps. Implementing incident-to billing in your practice doesn’t have to feel like rocket science. With the right workflow, you can keep things compliant, efficient, and profitable. Here’s how to set everything up for success.


Step 1: Establish Clear Roles in Your Practice

First things first, you need to define who’s doing what. Incident-to billing works best when every team member knows their role in the process:

  • Physician’s Role: The physician conducts the initial face-to-face visit, establishes the care plan, and provides supervision (direct or general, depending on the situation).
  • PA/NP Role: Deliver services

as per the physician’s care plan, document patient encounters thoroughly and ensure their scope of practice aligns with state laws.

  • Billing/Coding Team: Stay updated on payer-specific guidelines, verify documentation, and flag any visits that don’t meet incident-to billing requirements.

Having this clarity eliminates confusion and ensures compliance from start to finish.


Step 2: Build a Documentation Workflow

Documentation is your strongest defense against audits, so make it airtight. Here’s a simple workflow you can follow:

  1. Physician Encounter: Document the initial face-to-face visit and create a detailed care plan. Make sure the plan outlines the patient’s condition, goals, and the specific steps auxiliary staff will take in follow-up visits.
  2. Auxiliary Staff Notes: When PAs or NPs see the patient, their notes must clearly indicate they are following the established care plan. If the patient presents with a new issue, that must also be documented—and billed separately.
  3. Supervision Verification: Use a sign-in sheet or digital time-tracking system to confirm the supervising physician was on-site during the visit.
  4. Billing Checkpoint: Before submitting a claim, double-check that the documentation supports incident-to billing. Your billing team should verify that the physician’s NPI is used for claims that qualify.

Step 3: Train and Audit Your Staff

Staff training is key to implementing incident-to billing effectively. Consider these steps:

  • Initial Training: Educate your team on Medicare’s requirements for incident-to billing, including face-to-face encounters, supervision, and payer-specific nuances.
  • Ongoing Education: Medicare and payer rules can change. Stay ahead by scheduling regular training sessions for your team.
  • Internal Audits: Perform regular chart audits to ensure compliance. Flag visits that don’t meet incident-to billing criteria and adjust processes as needed.

Step 4: Use Technology to Your Advantage

If you’re not leveraging your EHR (Electronic Health Record) system to streamline incident-to billing, you’re missing out. Here’s how tech can help:

  • Templates: Create care plan templates within your EHR to ensure consistency and thoroughness.
  • Alerts: Set up alerts to remind your team when a physician’s supervision is required or if a visit doesn’t qualify for incident to billing.
  • Documentation Tags: Use tags or flags in your EHR to differentiate between visits that qualify for incident to billing and those that don’t.

Automation reduces human error and helps you maintain compliance.


Step 5: Evaluate Reimbursement Trends

Finally, keep a close eye on your reimbursement data. Compare how much your practice earns when billing under incident-to billing versus billing under auxiliary personnel directly. If you notice any discrepancies, dig into the details to uncover potential issues (like documentation errors or payer-specific rules).

Maximizing reimbursement doesn’t just happen—it’s a process of continuous improvement.


FAQ: Incident-To Billing Made Simple

What is incident-to billing?

Incident-to billing is a Medicare billing method that allows non-physician practitioners (NPPs) like nurse practitioners (NPs) and physician assistants (PAs) to bill under a physician’s NPI for 100% reimbursement instead of the standard 85%. However, this is only allowed if all incident-to billing guidelines are met.

Who can provide services under incident-to billing?

Only certain healthcare providers can bill incident-to, including:
Physician Assistants (PAs)
Nurse Practitioners (NPs)
Certified Nurse Midwives (CNMs)
Clinical Nurse Specialists (CNSs)
🚫 Registered Nurses (RNs) and Medical Assistants (MAs) CANNOT bill incident-to.

What are the key requirements for incident-to billing?

To bill incident-to, you must meet all of the following requirements:
✅ The physician must see the patient first and establish the treatment plan.
✅ The NPP must follow the physician’s plan of care—no diagnosing new conditions.
✅ The physician must be on-site (in the office suite) when the NPP provides services.
✅ The service must be provided in an office setting (not a hospital or skilled nursing facility).

Can an NP or PA diagnose a new condition under incident-to billing?

🚫 No! If a patient has a new diagnosis or medical issue, the physician must see the patient first before an NP or PA can provide follow-up care under incident-to billing. If the NPP treats a new condition, the service must be billed under their own NPI at 85% reimbursement.

What happens if the physician is not in the office?

If the physician is not physically in the office suite, incident-to billing is NOT allowed. The NPP must bill under their own NPI at 85% of the Medicare Physician Fee Schedule.

Can incident-to billing be used in a hospital setting?

🚫 No! Incident-to billing is only allowed in a physician’s office or private practice. It CANNOT be used in:
Hospitals
Skilled Nursing Facilities (SNFs)
Emergency Rooms

How does incident-to billing affect reimbursement?

When billed correctly, incident-to services are reimbursed at 100% of the Medicare rate. If billed under an NP or PA’s NPI, the reimbursement drops to 85% of the fee schedule.

ServiceBilled Under Physician (Incident-To)Billed Under NP/PA
Level 3 Office Visit$100$85
Level 4 Office Visit$150$127.50

What are the most common mistakes in incident-to billing?

🚨 Common mistakes that can trigger audits and denials:
Billing incident-to for new conditions (physician must see the patient first).
Not having the physician on-site (physician must be in the office suite).
Using incident-to in hospitals or SNFs (not allowed).
Failing to document physician supervision and care plan.

How should documentation support incident-to billing?

Your documentation must clearly state:
The physician conducted the initial visit and created the treatment plan.
The NPP followed the established plan without diagnosing new conditions.
The supervising physician was physically present in the office.
The visit qualifies for incident-to billing under Medicare rules.

Do commercial insurance payers allow incident-to billing?

Some commercial payers follow Medicare’s incident-to rules, but others have their own guidelines. Always check with your payer contracts and provider relations team to confirm requirements.

How can my practice avoid incident-to billing denials?

Train your staff on proper documentation and supervision requirements.
Use checklists and templates to ensure compliance.
Audit claims regularly to catch errors before submission.
Keep up-to-date with Medicare and commercial payer guidelines.


Wrapping It All Up

Incident-to billing can be a huge asset to your practice if you understand and follow the rules. While it may feel complicated at first, taking the time to master the requirements—such as the initial face-to-face visit, supervision rules, and detailed documentation—pays off with increased reimbursement and smoother operations.

Just remember: compliance is non-negotiable. A misstep here could trigger audits, repayment demands, and even penalties. But with a solid workflow, a well-trained team, and careful attention to payer requirements, you can confidently navigate the world of incident-to billing like a pro.