Hint: Doctor's schedule will be the key. On-site requirement: To bill certain services incident-to, the physician must be present in the office and be immediately available for assistance, consultation, or patient emergencies, should they arise, though not necessarily seeing the patient. "If the insurer ever audits your charts, the insurer can look at the doctor's schedule on the date of the incident- toservice," says Heather Corcoran with CGH Billing in Louisville, Ky. "If the doctor was out of the office and your NPP billed incident-to services that required his presence in the office, your insurer will have a lot of questions for you." Tip: Don't assume that just because the pulmonologist is involved in the patient's care, that the physician's services can be considered incident-to, says Randall Karpf of East Billing in East Hartford, Conn. The pulmonologist initiates the treatment and demonstrates involvement throughout the service via direct supervision. It is possible for another physician in the group to provide direct supervision on a day that the patient's primary physician is not available.