Wiki Billing "Incident to"

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camilla38

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Hi everyone,
I am still confused as to where on the claims form should we indicate that the NP/PA rendered the services as an "Incident to" The physician was in the same suite(direct supervision)but seeing other patients.
Should we put the NP/PA NPI number in line 24J and the supervising physicians information in Line 31 OR should we put the supervising physicians NPI in both Line 24J and line 31 on the claim????
To my understanding if the physician was in the room with the NP/PA providing personal direct supervision(starting off even for established patients) then we should put the physicians NPI in line 24J and 31 BUT if the NP/PA was alone in the room providing services, then the NP/PA NPI should be in line 24J to indicate that she/he rendered the services.
Someone said it does not matter if the physician is in the room or not with the NP/PA for the "Incident to" because only the SUPERVISING PHYSICIAN'S NPI WILL BE PUT IN LINE 24J and 31

Isn't this providing false information to Medicare? We are billing as if the M.D provided the services.
Now, HOW WILL MEDICARE OR OTHER PAYERS EVER KNOW THAT THE SERVICE BILLED WAS AN "INCIDENT TO". NOTHING IS INDICATED ON THE CLAIM FORM WHEN BILLING and so I am afraid alot of fraudulent billing is taking place.

Could someone please clarify this problem and provide literature for everyone.
I have read Medicare Benefit Policy Manual which is not very clear so everyone is interpreting it differently.
Chapter 15 – Covered Medical and Other Health Services
Table of Contents
(Rev. 157, 06-08-12) PAGE:81

Thanks.
 
NP/PA NPI goes in 24J and Supervising MD NPI goes everywhere else. That's how we do it at my practice and we've been through several Medicare audits without this being an issue.
 
Please see below links and references. As of right now, there is no requirement to identify the rendering provider when the service is incident to. The first link is from the claims processing manual, I underlined the part regarding who the provider in 24J is. The second is from a report the OIG did. They recommend developing a modifier to identify a service is incident to, which as of today has not been developed.

http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c26.pdf

Item 24J - Enter the rendering provider‟s NPI number in the lower unshaded portion. In the case of a service provided incident to the service of a physician or non-physician practitioner, when the person who ordered the service is not supervising, enter the NPI of the supervisor in the lower unshaded portion.

https://oig.hhs.gov/oei/reports/oei-09-06-00430.pdf

Medicare does not require identifiers on claims indicating that the service was furnished “incident to.”


Hope this helps,

Laura, CPC, CPMA, CEMC
 
Thanks.
This is the line that is so confusing:
In the case of a service provided incident to the service of a physician or non-physician practitioner, when the person who ordered the service is not supervising, enter the NPI of the supervisor in the lower unshaded portion.

Who does it refer to???????
 
Generally the physician that originally saw the patient and developed the plan of care is the the physician that the NPP is working under and the claim is submitted under. This line is in reference to cases when this provider is not the one supervising the NPP on that date.

In order for a service to be incident to the billing physician must be onsite in the office/suite when the service is provided.

In the case of a group practice it is not uncommon for NPPs to work under multiple physicians. So if Dr. A is the primary care and established the plan that the NPP is following but Dr. A is on vacation and Dr. B is the one in the office that day the claim goes under Dr. B.

Medicare sees physicians of the same specialty in the same group as the same person.

Side note, I just finished reading thru the OIG work plan for 2013, and they are still looking at incident to billing.

Laura, CPC, CPMA, CEMC
 
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