Medicare Compliance & Reimbursement

Incident-to rules apply to the relationship between a physician and a mid-level provider. If your group practice made an administrative decision to simplify the medical records by billing all services and all providers (including other physicians) under just the medical director's NPI, you could be headed for trouble. You cannot always bill services for all providers under a group's medical director. One reason is because you may not bill one doctor incident-to another doctor. Incident-to rules don't apply here because they pertain to the relationship between a physician and a midlevel provider (MLP), also known as a nonphysician practitioner (NPP). Bottom line: It is never acceptable to bill services provided by one physician under another physician's name or national provider identifier (NPI). Billing under the name of a physician who did not perform the service could lead to allegations of false claims submissions. You can, however, report MLP services incident-to [...]