Practice Management Alert

Brush up on incident-to, Locum Tenems, and reciprocal billing.

The Centers for Medicare & Medicaid Services (CMS) describes certain situations in which a provider can bill Medicare even if someone else performed the services reported. Medicare Administrative Contractors (MACs) describe these services accordingly:

Incident-to Services: “Incident to is defined as services or supplies that are furnished incident to a physician’s professional services when the services or supplies are furnished as an integral, although incidental, part of the physician’s personal professional services in the course of diagnosis or treatment of an injury or illness and services are performed in the physician’s office or in the patient’s home. To qualify for payment under the incident to rules, services must be part of the patient’s normal course of treatment, during which a physician personally performed an initial service and remains actively involved in the ongoing course of treatment,” says Noridian.

Incident-to services are frequently provided by a nonphysician practitioner (NPP), but the supervising physician must be “immediately available,” which does not necessarily mean occupying the same physical space, i.e., the physician should be in the practice but doesn’t need to be in the exam room.

Fee-For-Time Compensation: Formerly known as “Locum Tenens,” receiving fee-for-time compensation may be appropriate in situations when a substitute physician or physical therapist provides services in lieu of a patient’s regular physician or physical therapist because the latter is unavailable. This arrangement can occur per diem or on a fee-for-time basis, but cannot exceed 60 days, unless the original provider is called or ordered to active duty as a reserve component of the armed forces, says Novitas.

Reciprocal Billing: CGS says: “On an occasional reciprocal basis, a patient’s regular physician will arrange for a substitute physician to provide visit/services, including emergency visits or related services. Under a reciprocal billing arrangement, the patient’s regular physician may submit a claim to Medicare Part B using his/her own NPI and, if assignment is accepted, receive payment.” For legal reciprocal billing, the original physician must be unavailable, and the patient must have sought services from the original physician. Similar time period restrictions to Locum Tenens agreements apply.