Wiki Incident To Guidelines

[terribo]

I have a few questions/scenarios regarding "Incident to" guidelines. We want to make sure we are following the policy correctly.

1. If a PA or NP evaluates a New Patient OR Established Patient with a New Problem, and the supervising doctor IS NOT on Site, the claim must be filed under whose NPI? The PA/NP OR the supervising doctor?

2. If a PA or NP evaluates a New Patient OR Established Patient with a New Problem, and the supervising doctor IS ON Site, the claim must be filed under whose NPI? The PA/NP OR the supervising doctor?

3. Established patient with established problem seen by PA/NP, Supervising doctor is NOT on site, the claim is filed under whose NPI?

4. Established patient with established problem seen by PA/NP, Supervising doctor IS ON site, the claim is filed under whose NPI?

Thank you

 

[csperoni]

Remember not all carriers follow incident-to. Below are my answers only for carriers that follow Medicare's Incident-to:
1) If physician is not on site, ACP claims must be billed under the ACP.
2) If physician IS on site, ACP E&M services following the physician's already established plan of care may be billed under the physician. If it is a new problem, there cannot possibly be a plan of care, so must be billed under ACP.
3) See #1.
4) See #2.

 

[ibouzanquet]

I have a new question on incident to rule. Can a non-credentialed physician use incident to rule billing under a credentialed physician?

 

[csperoni]

I have a new question on incident to rule. Can a non-credentialed physician use incident to rule billing under a credentialed physician?

This question does come up periodically, usually regarding a provider new to the practice who has not yet gone through credentialing. If the question is whether or not it is possible, the answer (surprisingly) seems to be yes. However, in reality, I cannot imagine any fully licensed physician working as ancillary staff under the supervision of another physician, simply carrying out the established plan.
Potential huge issues:
1) Carrier does not follow incident-to
2) Patient needs a change to their treatment plan
3) Initial (participating) physician did not establish a treatment plan
4) New patient
5) New problem
While the article itself is now 10 years old, the guidance is sound: https://www.aapc.com/blog/26668-risks-abound-for-non-credentialed-physicians-using-incident-to-rule/
Summary: CAN you? Yes, it is possible. SHOULD you? Absolutely NOT!

 

[Pam Warren]

Rather than bill the non-credentialed provider incident-to, know that Medicare does allow providers to retroactively bill from the date their application for credentialing was received, up to a year previously.