General Surgery Coding Alert

Just one physician will do.

You just honed your “incident-to” coding skills with the preceding story — but all that might change if a proposal in the July 15 Medicare Physician Fee Schedule (MPFS) final rule goes into effect.

Current way: You bill the incident-to services under the provider number of the physician who established the care plan that the NPP is carrying out. But you can list on the claim any doctor in the office as the physician providing direct supervision for the NPP.

Proposed 2016 way: In the proposed fee schedule, CMS suggests paying for incident-to services only if the doctor who bills for the incident-to service is the same person directly supervising the care.

“To be certain that the incident to services furnished to a beneficiary are in fact an integral, although incidental, part of the physician’s or other practitioner’s personal professional service that is billed to Medicare, we believe that the physician or other practitioner who bills for the incident to service must also be the physician or other practitioner who directly supervises the service,” CMS says in the proposed rule.

Additionally: CMS proposes that the person providing the incident-to service does so in accordance with state law and is licensed to do it. The incident-to provider also cannot have been excluded from any federal health care program or have had their enrollment revoked for any reason. In other words, just because the service is billed under a supervising doctor’s number doesn’t mean the performing NPP can be excluded from Medicare.