Question: In the multispecialty world, is it acceptable to bill under incident-to criteria if a physician from another specialty, such as internal medicine, provides the direct supervision over NPs and PAs in endocrinology? If the endocrinologist is not present in the office and another physician supervises, should we still submit claims using the physician's ID number?
Georgia Subscriber
Answer: Yes, incident-to rules state that the supervisor may be a different physician than the physician who established the patient's original plan of care (in this case, the endocrinologist). You should apply this rule consistently: The supervising physician is the physician on-site and available on the date of service, not the physician who previously supervised the patient's plan of care.
Remember always to submit your claims using the ID number of the supervising physician on the date of service. So, if your endocrinologist is not present and does not supervise, you should not use his ID number. Rather, you should bill under the ID number of the in-office supervising physician. Of course, if multiple physicians are on-site and available and one of them is the physician who initiated the patient's care, you should bill under his ID number.
Using the ID number of the supervising physician on duty makes sense in terms of billing compliance. If a carrier looks at your scheduling records and sees that you billed services under the ID of a physician who was on vacation or out of the office, that could spark an audit.
