# Reciprocal billing and incident to



## Lisa Bledsoe (Apr 16, 2010)

My question is in regards to NPP's and physician supervision in a group practice.  If the NPP is supervised under Dr. X but on the date of a qualified incident to visit, Dr. X is out of the office but Dr. Y is in the office - does the incident to claim get billed under the NPP and Dr. X (is this reciprocal billing?) or the NPP and Dr. Y?  Where do I find this information please?


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## LLovett (Apr 16, 2010)

I don't know if you will find something that gets a specific as this but when you break it down to the 2 basic issues you can base it on the regular incident to guidelines.

1. Medicare sees providers of the same specialty in the same group as the same individual. 

2. To be incident to the doctor you are billing under has to be in the office/suite during the time of service.

So in your case you would bill the service as incident to (assuming it meets the guidelines) under the doctor that is physically there. Medicare doesn't care that 2 different doctors are involved, they just see claims from one specilaty in that one group. I have gotten this verbally confirmed from WPSMedicare as well, but I know it would be better to have it in writing.

Hope that helps,

Laura, CPC, CPMA, CEMC


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## Lisa Bledsoe (Apr 16, 2010)

Thanks Laura - that's my view, but I'm being asked for specific documentation...you know how easy that is to come by!  I appreciate your input!


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## RebeccaWoodward* (Apr 16, 2010)

This section of CMS guidance also supports billing under the physician who is actually present in the suite/office for "incident-to" purposes.


A physician directed clinic is one where (a) a physician (*or a number of physicians*) is present to perform medical (rather than administrative) services at all times the clinic is open; (b) each patient is under the care of a clinic physician; and (c) the nonphysician services are under medical supervision.

In highly organized clinics, particularly those that are departmentalized, *direct physician supervision may be the responsibility of several physicians *as opposed to an individual attending physician. *In this situation, medical management of all services provided in the clinic is assured*

https://www.cms.gov/transmittals/downloads/R1764B3.pdf

Page 5


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## Lisa Bledsoe (Apr 16, 2010)

Awesome - thanks Rebecca!


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