Question: We recently hired a nurse practitioner at our ophthalmology office and have never had an NP on staff before. We’re looking into how we can bill incident-to services for her work. We know that the doctor needs to initiate the treatment plan, but beyond that we aren’t totally sure what we have to do. Can you advise? Codify Subscriber Answer: You’re correct in noting that the NP must be treating the patient in accordance with the physician’s treatment plan. In addition, all incident-to services require direct supervision by the physician, which means that the supervising physician must be immediately available within the office suite. Additionally, the NP must be providing services within his/her scope of practice as determined by state law in which the NP practices. There can be no changes to the treatment plan by the NP (including medication changes) or new problems assessed by the NP to bill incident-to compliantly. If any changes are made or new problems are assessed, the visit must be billed under the NP’s NPI and is subject to 85 percent reimbursement. Because the physician must establish the initial treatment plan, it’s important to keep in mind that incident-to services only apply to established patients and not to new patients.