Wiki Do other payers allow incident-to billing?

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Is Medicare the only payer that allows incident-to billing? I can't seem to get a straight answer from anywhere I've looked. We have medical assistants who perform injections and blood draws but I don't know if we can bill those services as incident-to to all payers or just Medicare.
 
Are you truly billing Medical Assistant (MA) services to Medicare under the "Incident To Services & Supplies" provision of the physician fee schedule? According to the Medicare only Advanced Practice Nonphysician Practitioners (APNP) are able to bill as incident to a physician and must enroll with Medicare in order to do so. They specifically list the following practitioners as eligible to bill as incident to:
  • Advanced Practice Registered Nurses (APRNs)
    • Certified Registered Nurse Anesthetists (CRNAs)
    • Nurse Practitioners (NPs)
    • Clinical Nurse Specialists (CNSs)
    • Certified Nurse-Midwives (CNMs)
  • Physician Assistants (PAs)
As for your question about whether other payers allow incident to billing, each payer has their own rules, although many follow the Medicare guidelines. I have worked in the commercial health insurance industry for 20+ years and I've never worked for a payer who would credential and enroll a MA and reimburse them for services. The service of an MA is considered part of the clinic staff and are under the direction of the physician or nonphysician practitioner and as long as the services performed are within the scope of their license of the state where they are working, their services would be bill under the physician or nonphysician practitioner along with the services performed directly by the provider.
 
Are you truly billing Medical Assistant (MA) services to Medicare under the "Incident To Services & Supplies" provision of the physician fee schedule? According to the Medicare only Advanced Practice Nonphysician Practitioners (APNP) are able to bill as incident to a physician and must enroll with Medicare in order to do so. They specifically list the following practitioners as eligible to bill as incident to:
  • Advanced Practice Registered Nurses (APRNs)
    • Certified Registered Nurse Anesthetists (CRNAs)
    • Nurse Practitioners (NPs)
    • Clinical Nurse Specialists (CNSs)
    • Certified Nurse-Midwives (CNMs)
  • Physician Assistants (PAs)
As for your question about whether other payers allow incident to billing, each payer has their own rules, although many follow the Medicare guidelines. I have worked in the commercial health insurance industry for 20+ years and I've never worked for a payer who would credential and enroll a MA and reimburse them for services. The service of an MA is considered part of the clinic staff and are under the direction of the physician or nonphysician practitioner and as long as the services performed are within the scope of their license of the state where they are working, their services would be bill under the physician or nonphysician practitioner along with the services performed directly by the provider.
We have the MA do injections or blood draws and we bill it under the supervising provider's NPI. Is that not what incident to billing is? I've never been very clear on what is actually means.
 
We have the MA do injections or blood draws and we bill it under the supervising provider's NPI. Is that not what incident to billing is? I've never been very clear on what is actually means.
Yes, there is incident to billing when APNP provide physician services and there is incident to billing for auxiliary personnel (like nursing services). See CMS Benefit Policy Manual, Chapter 15, Section 60, "When their services are provided as auxiliary personnel (see under direct physician supervision, they may be covered as incident to services, in which case the incident to requirements would apply...Thus, where a physician supervises auxiliary personnel to assist him/her in rendering services to patients and includes the charges for their services in his/her own bills, the services of such personnel are considered incident to the physician’s service if there is a physician’s service rendered to which the services of such personnel are an incidental part and there is direct supervision by the physician."

Mostly when incident to billing is described, it's typically in the advanced non-physician practitioner situation, and level of supervision is discussed when it's auxiliary personnel.
 
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