Practice Management Alert

Answer: Yes, you can bill incident-to services under Dr. Richard's provider number. The supervising physician for the incident-to service is not required to be the same physician who initially saw the patient, nor does the supervising physician have to be of the same specialty as the initial physician. However, the NPP must be an employee of the physician (group).

Remember that to bill incident-to services under a physician's PIN number, the services must be for an established patient. If the patient is new or presents with a new problem, you must bill under the NPP's number.

In addition, the physician must have provided direct personal supervision over the services rendered. Direct personal supervision means the physician is in the office space. So if the physician is in the hospital but only available by phone, even if the hospital setting is down through a tunnel, you cannot bill incident-to. The physician is not, however, required to be in the same room at the time of service.

Advise your NPP to document in the progress notes or patient charts the name of the physician who supervised the service. This note lets anyone reviewing claim know that your NPP was aware of the supervision of the physician and shows that you're billing incident-to services appropriately.

Medicare auditors are now checking copies of office schedules, so you want to make sure your NPP's documentation matches up to the schedule, indicating that again, you're billing incident-to correctly.