# Incident-to POS question



## coachlang3 (Jul 9, 2013)

I usually only do physician hospital and ASC claims so I'm not completely educated on in-office E/M and incident to guidelines.

My questions is this:  The practice I work for owns an ASC that is directly attached to our physician offices.  I mean attached by an unlocked, two way door between the two areas on the same floor of the same building.  Does this qualify as the doctor being in the office suite as long as they are immediately available for assistance if a NPP is doing the work in the office suite?  As I said the practice owns the ASC, not sure if that makes a difference.

Thanks,
Fred


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## nyyankees (Jul 9, 2013)

coachlang3 said:


> I usually only do physician hospital and ASC claims so I'm not completely educated on in-office E/M and incident to guidelines.
> 
> My questions is this:  The practice I work for owns an ASC that is directly attached to our physician offices.  I mean attached by an unlocked, two way door between the two areas on the same floor of the same building.  Does this qualify as the doctor being in the office suite as long as they are immediately available for assistance if a NPP is doing the work in the office suite?  As I said the practice owns the ASC, not sure if that makes a difference.
> 
> ...



If they are in ASC performing surgery I say no.


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## OCD_coder (Jul 9, 2013)

This was a scenario that was presented to Michael Miscoe, esq. at the 2013 AAPC Conference in Incident To rules.  

Incident to would apply; If the supervising provider can be immediately available to the staff member performing the service, meaning if they can be called and in the room face to face with the patient within 2 minutes tops, then this would qualify for incident to billing rules.  So they can next door, the floor above or below the suite to where the patient is being treated.

If the provider is performing surgery, they will not stop surgery to be accessible to the NPP provider to care for the patient receiving incident to services in the clinic.  Incident to billing would not apply.

If you employer has specific rules to apply to "supervising provider" this trumps all the above information.


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## coachlang3 (Jul 9, 2013)

That's what I had figured would be the case.  Of course if they were immediately available then they would be in their own office and not hanging out in the ASC unless actually doing surgery.

Thanks gang!!


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## cheermom68 (Jul 9, 2013)

WPS stated at a recent seminar that the physician must be in the "office suite", which means that set of rooms/offices that are a part of that particular practice, and immediately available.


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## mhstrauss (Jul 9, 2013)

cheermom68 said:


> WPS stated at a recent seminar that the physician must be in the "office suite", which means that set of rooms/offices that are a part of that particular practice, and immediately available.



Novitas has stated this same guideline.  I would think being "in the nearby ASC" would not qualify for Incident-To.


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## coachlang3 (Jul 9, 2013)

This ASC is part of this practice and not just nearby, it is physically attached to the suite of offices.  The doctors are literally about 20 feet from the exam rooms to the procedure rooms.  That's why I asked the question originally to see how Medicare viewed a practice-owned ASC that is physically attached to the medical office suites.  Do they consider it an extension or not?  That's all.

Thanks for the input everyone.  Plus I've learned some new stuff!!!


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