Wiki Incident-to billing

[kathleeng]

Question, for incident-to billing, does the supervising doctor need to be of the same sub-specialty, or can it be by a supervising doctor of a different specialty taxonomy number? Example Med-Onc and Gyn-Onc, both are of oncology but different sub-specialties and different specialty taxonomy numbers. My interpretation of the guidelines has been that they must be of the same sub-specialty, however I would be interested to know if there is publication of more specific direction on this area.

 

[thomas7331]

Question, for incident-to billing, does the supervising doctor need to be of the same sub-specialty, or can it be by a supervising doctor of a different specialty taxonomy number? Example Med-Onc and Gyn-Onc, both are of oncology but different sub-specialties and different specialty taxonomy numbers. My interpretation of the guidelines has been that they must be of the same sub-specialty, however I would be interested to know if there is publication of more specific direction on this area.

I have never heard of this requirement, and am not sure what guidelines you're referring to that would suggest this might be the case. For one thing, mid-level providers (PAs, NPs) whose services are the ones most often billed as 'incident-to', do not usually have any sub-specialty assigned to them. And certainly, the office staff (RNs, MAs, etc.) don't have a sub-specialty either. The point of billing 'incident-to' is that you are billing services that are wholly performed under the orders and direct supervision of the physician. Under this arrangement, the individual does not have any authority to initiate or alter those services in any way, and so their specialty, if they have one, isn't relevant at all.

 

[csperoni]

Incident-to is primarily used for staff - RN, MA, LNP, PA, NP, CNM, etc. While it is permitted for physicians, I do not know of any physician (other than an intern, resident or fellow) who actually works as ancillary staff under the supervision of another physician simply carrying out the plan of care of another physician. It's generally simply a bad idea.
https://www.aapc.com/blog/26668-risks-abound-for-non-credentialed-physicians-using-incident-to-rule/

Whether or not a medonc is legally qualified to supervise a gynonc I don't believe is addressed in incident-to billing guidelines. Perhaps state regulations since the state licenses the physician?
Regardless, I still think its a bad idea. All physicians should be credentialed. If the gynonc plan was taxol 175 mg/m² IV over 3 hours and the medonc needed to dose reduce due to side effects or lab results, that can no longer be incident-to.

 

[amyjph]

I agree with Thomas. I have never seen this requirement and don't know which guidelines you mean.
This is a good tool on the FCSO site that might help you understand the requirements: https://tools.fcsomedicare.com/apps/incidents

It has to be a physician who's a member of the group or practice providing direct supervision at the time of service. I have never seen a requirement related to specialty or subspecialty.