Should You Bill This Visit as “Incident to”?

Q. A physician hires a nonphysician practitioner (NPP), such as a physician assistant or advanced practice nurse practitioner, and establishes a standing delegation order for treatment of patients with pelvic floor dysfunction. The treatment involves three therapy visits and a progress evaluation on the fourth visit.

A Medicare patient presents with the diagnosis, and the NPP performs the initial visit and the three subsequent therapy visits. The physician evaluates the patient’s progress at the next visit. Do you bill the NPP visits as “incident to”?

A. No. Although the delegation may have been appropriate under Texas Medical Board rules, billing the services “incident to” is inappropriate because the physician did not initiate the course of treatment. 

The first four visits should have been billed under the NPP’s billing number and only the last visit under the physician.

To bill the visits under “incident to,” the physician must see the Medicare patient for the initial visit. The NPP must have his or her own provider number to bill for the visits.

For more information, see these TMA resources:

Published Oct. 19, 2017

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October 19, 2017

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