Question: Our ED physician performs nebulizer treatments. What documentation gets this service paid? Colorado Subscriber Answer: Because the incident-to rules do not apply in the ED, the physician would have to perform the service to bill for it. Occasionally, a physician's extra expertise is required to perform a nursing function. Examples of this include peripheral IV starts and difficult Foley catheters. Proper documentation for these treatments includes a description of the procedure and why it was "bumped up" to the physician. Finding a reason why a physician's extra training would be useful in giving a nebulizer treatment, however, may be difficult. This scenario most likely does not pass scrutiny in the area of medical necessity. Include the work in the E/M documentation, and don't risk charging it out separately unless you can absolutely prove medical necessity. In the end, this service would likely be bundled into the E/M.