Incident to Billing Performed by a Nurse Practitioner or Physician Assistant

Billing for services Performed by a Nurse Practitioner or Physician Assistant can be critical to your practice making sure you are maximizing reimbursement and you are not losing money.

incident to billing

These services are described as incident to billing.

Incident to billing for services that 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.
Note:  Incident to billing services are also relevant to services supervised by certain non-physician practitioners such as physician assistants, nurse practitioners, clinical nurse specialists, nurse midwives, or clinical psychologists. These services are subject to the same requirements as physician-supervised services. Remember that incident to billing for services supervised by non-physician practitioners are reimbursed at 85 percent of the physician fee schedule.

For clarity’s sake, this article will refer to “physician” services as inclusive of non-physician practitioners.

To qualify as incident to billing for provider 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. You do not have to be physically present in the patient’s treatment room while these services are provided, but you must provide direct supervision, that is, you must be present in the office suite to render assistance, if necessary. The patient record should document the essential requirements for incident to service.

Keypoints for Incident to Billing Services:

  1. The health giver is receiving direct supervision from the medical physician on the date of service.
  2. The service is a part of the current treatment plan of which the medical physician did the initial evaluation, plan of treatment and course of treatment.
  3. The supervising physician is actively involved in the course of treatment.

Health Providers such as Physician Assistants, Nurse Practitioner, Physical Therapists, Occupational Therapists & Speech Therapists are example of health providers that might me providing services under the group or a solo practitioner.

These providers are all under the direct supervision of the Medical Doctor who did the initial evaluation, plan of care and course of treatment. Services are rendered to patients as if the supervising MD saw the patient himself.

If the Insurance Companies that your practice participates with credentials for instance the PAs, upon issuance of his/her provider number with the insurance company, your practice must start billing that insurance company under his/her provider number rather than using the supervising MDs provider number, under the group number or tax ID number.

Though incident to billing services are being paid at 85% (MEDICARE) based on the Physician Fee Schedule. The Supervising MDs must be present on the same suite/floor with the supervised health giver. Not necessarily on the same treatment room.

The following Scenarios are being sited by Medicare – let’s take a look …

“Must a supervising physician be physically present when flu shots, EKGs, Laboratory tests, or Xrays are performed in an office setting in order to be billed as “incident to” services?”
These services have their own statutory benefit categories and are subject to the rules applicable to their specific category. They are not “incident to” services and the “incident to” rules do not apply.

“Can anti-coagulation monitoring be provided incident to billing for a physician’s services in an office?”
Yes, if the requirements are met, i.e., the services are part of a course of treatment during which the physician personally performs the initial service and is actively involved in the course of treatment, is physically present in the immediate office when services are rendered by the employee, and the service represents an expense to the physician or other legal entity that bills for the service.

“If the treating physician (Doctor X) refers a patient to an anti-coagulation monitoring clinic, can Doctor X bill do an incident to billing for services?
No, because the services are not being provided by an employee under supervision of Doctor X.

“Can the supervising physician (Doctor Y) at the anti-coagulation monitoring clinic (a physician group) can do incident to billing for services if Doctor Y directly supervises those services at the clinic?”
No, because Doctor Y is not treating the patient for the underlying condition. However, If Doctor Y receives a referral from Dr. X, and Dr. Y performs an initial evaluation of the patient and then orders and supervises the services, they may be billed by Doctor Y incident to billing her initial service.


Sources and References for Incident to Billing can be found below:

Chapter 12 – Physicians Nonphysician Practitioners-Rev 3096 30.6.4 – Evaluation and Management (E/M) Services Furnished Incident
to Physician’s Service by Nonphysician Practitioners

Incident to Billing Services Per Medicare SE0441


Ms. Pinky Maniri - Your Partner to Grow your Medical Practice (848) 863-9108

Ms. Pinky Maniri – Your Partner to Grow your Medical Practice (848) 863-9108

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Author: Pinky Maniri

Ms. Pinky, as she is fondly called - is a Reputable Professional Consultant and Expert in Practice Administration, Medical Billing, Coding, Health Information Technology, Insurance Credentialing and Compliance for Physician Offices. Well-educated with a Degree in Computer Systems Engineering and a background in Clinical Nursing and Small Business Management. Her professional mission is to make sure her clients/physicians maximize reimbursement while they remain compliant with the current rules, changes, guidelines and policies. Read More About Ms. Pinky here and See what Other's say about her Expertise Testimonials

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