# Telehealth - Incident to ?



## glielmia (May 1, 2020)

Incident-to Telehealth Supervision - Is this an approach open to us during the Covid emergency that we use to bill out supervising MD rates instead of NP?


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## thomas7331 (May 1, 2020)

CMS has relaxed the definition of direct supervision during the emergency to allow providers to supervise staff using technology rather than having to be present in the building.  Except for this change in supervision though, all other requirements of 'incident to' billing must still be met in order to bill a service under the supervising MD, as far as I'm aware.

_"For telehealth services that need to be personally provided by a physician, such as an E/M visit, the physician would need to personally perform the E/M visit and report that service as a Medicare telehealth service....  Other services, including both face-to-face and non-face-to-face services, could be provided incident to a physicians’ service by a nurse or other auxiliary personnel, as long as the billing practitioner is providing appropriate supervision through audio/video real-time communications technology (or in person), when needed....

For the reasons discussed above, on an interim basis for the duration of the PHE for the COVID-19 pandemic, we are altering the definition of direct supervision..to state that necessary presence of the physician for direct supervision includes virtual presence through audio/video real-time communications technology when use of such technology is indicated to reduce exposure risks for the beneficiary or health care provider." _

You can find the full statement of the new guidance here: 
_


			https://www.cms.gov/files/document/covid-final-ifc.pdf
		

_


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## faraasha624 (May 21, 2020)

Is it allowable for a APRN to bill out under a different APRN due to training in telehealth? This is for commercial and Medicaid- not Medicare.


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## csperoni (May 21, 2020)

Telehealth or not, NPPs may not bill incident to another.  Incident to is for NPPs billing under physician.  
The claim should be billed under the APRN who rendered the service, even if another APRN was present to teach him/her about telehealth.


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## Gioisdknite (Aug 16, 2022)

Good morning everyone,
I am trying to find verbiage under CMS and elsewhere to see if these relaxed rules still apply. Can someone please direct me or confirm if Telehealth services may still be provided under Incident-to scenarios? Thank you in advance.


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## csperoni (Aug 16, 2022)

Gioisdknite said:


> Good morning everyone,
> I am trying to find verbiage under CMS and elsewhere to see if these relaxed rules still apply. Can someone please direct me or confirm if Telehealth services may still be provided under Incident-to scenarios? Thank you in advance.


From Thomas' post above, "_on an interim basis for the duration of the PHE for the COVID-19 pandemic"._
The current PHE is extended through at least October 13, 2022.


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## Gioisdknite (Aug 16, 2022)

Good afternoon Christine,

Thank you for prompt response. I truly do appreciate your input and confirmation. I shall relay the information to my team.

Hope you have a wonderful rest of your day.


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