Question: Our ED physician performs nebulizer treatments. What documentation gets this service paid? Michigan Subscriber Answer: Because the "incident-to" rules do not apply in the ED setting, the physician would have to perform the service themselves to bill for it with a medical necessity requirement and consideration of the supply cost. Occasionally, a physician's expertise is required to perform what would normally be a nursing function. Examples of this include starting a peripheral IV and difficult Foley catheter insertions. Proper documentation for these treatments includes a description of the procedure and why the physician's expertise was required. Finding a reason why a physician's additional training would be useful in giving a nebulizer treatment, however, may be a hard case to make.