# Medicare Advantage Plans and Incident To Rules



## kelam (Oct 26, 2012)

Looking for some advice on billing Medicare Advantage plans.  We have an office offsite from our medical offices where we perform MNT(medical nutririon training) and DSMT (diabetic self management training), there are no physicans that see patients in this offsite office, we have an RD and a PA in this office.  The question is, can you bill incident to the physican for a Medicare Advantage plan if the physican is signing off on the training but not physically in the building?  Or should we have to follow the rules of regular medicare and only bill under the provider performing the service since they are not under direct supervision? 


I appreciate any feedback!

-Katie


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## mitchellde (Oct 26, 2012)

You cannot bill under a physician that is not either rendering or supervising the patient at the time of the service.  So no you will have to bill using the NPI of the one performing the service.


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## Texascoder64 (Oct 30, 2012)

Debra, have a question for you.  On the commercial carriers(NON medicare) where the incident rule does not apply. When I call the ins company they say they do not require our PA to be credentialed because we bill under the same group NPI# on our contract.  This seems like a gray area to me and I am unclear  if that is the case, if the PA renders the care - do we have to bill under the PA or can we bill under the supervising Drs #'s as if the Dr was the provider?  This is so confusing to me since they will not be very specific.


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## mitchellde (Oct 30, 2012)

The AMA a couple of years back stated that you need the carriers specific policy on incident to in writing, and it must clearly state that they understand that the PA or NP may be seeing a patient that the provider has never seen or has not seen for this dx, or that the provider may even be out of the office at the time of service.  Otherwise with this information in writing from the specific carrier you must assume that they do follow Medicare policy.  Medicare is the gold standard for reimbursement policies and it is generally accepted that unless they state otherwise they do follow Medicare.  I have found that all of the commercial carriers I deal with do in fact follow Medicare for the incident to policy.  Which means if the provider is not in the office at the time of service or this is a new patient or new problem you bill using the PA NPI number, If the PA is not credentialed then the visit may be treated as out of network.


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