Effective Oct. 25, 2002, CMS will allow incident-to billing for hospital inpatient, outpatient and ED evaluations when both a physician and a nonphysician practitioner (NPP) see the patient. According to CMS Transmittal 1776, when an NPP and a physician from the same group practice share a patient evaluation "and the physician provides any face-to-face portion of the E/M encounter," the service may be billed under either the physician's or the NPP's PIN number. This eliminates the former "split billing" version of NPP inpatient services. Unlike outpatient incident-to billing, however, the NPP cannot bill incident-to if the physician simply reviews the patient's chart.The physician must have a face-to-face encounter with the patient to bill incident-to for inpatients.
The full text of the transmittal is available on the CMS Web site at
www.cms.hhs.gov/manuals/pm_trans/R1776B3.pdf.
