Pathology/Lab Coding Alert

Hint: The key is recognition and supervision

If the term "incident-to" leaves you perplexed, our experts help you to break down Medicare's guidelines and avoid mistakes when billing nonphysician services.

Only Bill for Recognized Practitioners, Please

Only physicians and certain nonphysician practitioners recognized by Medicare can bill for services they provide incident-to a physician's professional service. And the recognized provider rendering the service must be practicing within his scope of practice as defined by state law, says Mary Mulholland, BSN, RN, CPC, a reimbursement analyst for the office of clinical documentation at the University of Pennsylvania's department of medicine in Philadelphia. Pathologists' assistants are not recognized providers, according to Medicare.

Physician Performs Initial Service

To bill under a physician's provider number, the physician must see the patient before any incident-to services begin. Medicare's incident-to guidelines state that a physician must institute a plan of care, and then the nonphysician practitioner can follow up with the patient, says Mary Falbo, MBA, CPC, president of Millennium Healthcare Consulting Inc. in Lansdale, Pa.

Get Straight Answers on 'Direct Supervision'

Another important incident-to billing requirement is that the nonphysician practitioner must provide the services under a physician's "direct supervision." Direct personal supervision does not mean that the physician must be present in the same room with the nonphysician practitioner, Falbo says. Rather, the supervising physician must be in the office suite and immediately available to provide assistance and direction to the nonphysician practitioner, she says. You'll have to document the supervision.