Medicare Blog

when billing for medicare patients, what is the advantage of "incident to" billing

by Joan Lowe I Published 1 year ago Updated 1 year ago

The advantage is that, under Medicare rules, covered services provided by NPPs typically are reimbursed at 85 percent of the fee schedule amount; whereas, services properly reported incident to are reimbursed at the full fee schedule value. To realize the benefits of incident to billing, you must follow the rules precisely.

The advantage is that, under Medicare rules, covered services provided by non-physician providers (NPPs) are typically are reimbursed at 85 percent of the fee schedule amount, whereas, services properly reported incident to are reimbursed at 100 percent of the full fee schedule value.

Full Answer

What are the advantages of incident to billing?

The advantage is that, under Medicare rules, covered services provided by NPPs typically are reimbursed at 85 percent of the fee schedule amount; whereas, services properly reported incident to are reimbursed at the full fee schedule value. To realize the benefits of incident to billing, you must follow the rules precisely.

What is “incident to” in Medicare billing?

“Incident to” is a Medicare billing provision that allows a patient seen exclusively by a PA to be billed under the physician’s name if certain strict criteria are met. Medicare reimburses at 100% when a PA- or APRN-provided service is billed under a physician and 85% when those same services are billed under the name of a PA or APRN.

What is incident-to-billing?

Incident to billing applies only to Medicare; and, the incident-to billing does not apply to services with their own benefit category. Diagnostic tests, for example, are subject to their own coverage requirements.

Can a service be billed as an incident to?

They are not “incident to” services and the “incident to” rules do not apply. 2. The service billed incident to must take place in a “noninstitutional setting,” which the Centers for Medicare & Medicaid Services (CMS) defines as “all settings other than a hospital or skilled nursing facility.”

Does Medicare Cover incident to billing?

“Incident to” billing only applies in the office or clinic setting (not in a hospital or facility) and requires that certain additional conditions be met such as ensuring that the physician: treat the patient during the initial visit for the medical condition; establish a diagnosis and treatment plan; and.

What does incident to mean Medicare?

“Incident to” services are defined as those services that are furnished incident to physician professional services in the physician's office (whether located in a separate office suite or within an institution) or in a patient's home.

What is incident to billing mean?

Incident-to billing is a way of billing outpatient services (rendered in a physician's office located in a separate office or in an institution, or in a patient's home) provided by a non-physician practitioner (NPP) such as a nurse practitioner (NP), physician assistant (PA), or other non-physician provider.

What is the modifier for incident to billing?

USING THE SA MODIFIER To qualify as “Incident To”, services must be part of the patient's normal course of treatment, during which a physician personally performed an initial service and remains actively involved in the course of treatment.

What is the advantage of incident to billing?

Under incident to billing, the mid-level services are actually billed under the physician's NPI number and not under their own number. It helps if you remember this concept as incident to billing has a large physician role that must be performed and documented in order to qualify for the 100% reimbursement.

What does Incident service mean?

“Incident to” services are defined as those services that are furnished incident to physician professional services in the physician's office (whether located in a separate office suite or within an institution) or in a patient's home.

What qualifies an incident?

INCIDENT-TO SERVICES Must relate to a service initially performed by the physician. Must be performed under direct supervision – when the physician is in the office suite/building. Cannot be billed when more than 50 percent of the visit is for counseling or care coordination. May not include diagnostic testing.

Can a physician Bill incident to another physician CMS?

The Centers for Medicare & Medicaid Services (CMS) has verified that a physician can bill for incident-to services rendered by another physician as long as all incident-to criteria is met.

What is CPT incident E&M code?

The CPT® code 99211 is the only E&M code used for 'incident to' billing available to the physician clinic's ancillary staff members. Some of the other codes (in the range of 99212–99499) can, however, be billed 'incident to' by non-physician providers (NP, PA, CNS).

Does incident need modifier?

No, there is no modifier when you bill "incident to".

Does Medicare require the SA modifier?

Medicare does not accept modifier SA, and other payers may specify unique requirements.

When should SA modifier be used?

SA = use when billing on behalf of a PA, ANP, or CRNFA for non-surgical services. (Modifier SA is used when the PA, ANP, or CRNFA is assisting with any other procedure that does not include surgery.)

What is incident to in AAPA?

What is “incident to?”. “Incident to” is a Medicare billing provision that allows a patient seen exclusively by a PA to be billed under the physician’s name if certain strict criteria are met.

What is a Medicare summary notice?

Patients may be confused when they receive a Medicare Summary Notice (MSN) that lists a health care professional who did not treat them. The MSN may list the name of a physician when the patient had all of their care delivered by a PA. In addition, a patient’s tests results may be misdirected to a physician when the results should be directed ...

Does MedPAC have the ability to change Medicare?

MedPAC does not have the ability to create new or change existing Medicare policies. That responsibility rests with Congress, the U.S. Department of Health and Human Services, and/or CMS. In the June 2019 report, MedPAC recommended that the Medicare program eliminate “incident to” billing for PAs and APRNs and calls for all medical services ...

Can a patient's test results be misdirected to a physician?

In addition, a patient’s tests results may be misdirected to a physician when the results should be directed to the PA who is treating the patient. “Incident to” billing also hides the positive impact of PAs on patient care and the health care system.

Can an APRN be billed under the PA's name?

The use of “incident to” billing is optional, and services delivered by PAs and APRNs can always be billed under the PA’s or APRN’s name, as authorized by state law. 2.

What is incident billing?

Incident to billing allows non-physician providers (NPPs) to report services “as if” they were performed by a physician. The advantage is that, under Medicare rules, covered services provided by non-physician providers (NPPs) are typically are reimbursed at 85 percent of the fee schedule amount, whereas, services properly reported incident to are reimbursed at 100 percent of the full fee schedule value.

Who must be employed by the group entity billing for the incident to service?

Both the credentialed physician and the qualified NPP providing the incident to service must be employed by the group entity billing for the service. If the physician is a sole practitioner, the physician must employ the NPP. The incident to service must be of a type usually performed in the office setting and must be part of the normal course ...

Does incident to billing apply to Medicare?

Incident to billing requirements are detailed in the Medicare Benefit Policy Manual, Chapter 15, Section 60. Incident to billing applies only to Medicare. Incident to billing does not apply to services with their own benefit category. Diagnostic tests are subject to their own coverage requirements.

Can incident to services be rendered on first visit?

Incident to services cannot be rendered on the patient’s first visit, or if a change to the plan of care occurs. A Medicare-credentialed physician must initiate the patient’s care. If the patient has a new or worsened complaint, a physician must conduct an initial evaluation and management (E/M) service for that complaint and must establish ...

Is a diagnostic test subject to its own coverage requirements?

For Example: Diagnostic tests are subject to their own coverage requirements. “Depending on the particular tests, the supervision requirement for diagnostic tests or other services may be more or less stringent than supervision requirements for services and supplies furnished incident to physician’s or other practitioner’s services.

Is incident to billing a Medicare or Medicaid?

Incident to billing services must take place in a "noninstitutional setting," which the Centers for Medicare and Medicaid Services (CMS) ...

What is incident to billing?

Incident to billing is a method of providing a service in which a physician or non-physician practitioner is not the individual actually providing the professional services which will later be billed to Medicare or Medicaid. The most popular utilization of “incident to” billing relates to the interactions between nurse practitioners or physician assistants and physicians. In this type of arrangement, a physician will initially treat the patient and then follow up visits will be provided by a nurse practitioner or physician assistant.

Why is it so hard to maintain compliance when billing incident to?

Finally, incident to billing can be problematic in settings in which a patient may come to the office for reasons outside of the initial diagnosis.

How much did the physician settle for in the incident to allegations?

The physician and the practice resolved the allegations by settling for nearly $100,000. “through this data mining, government investigators were able to determine that the Center had billed for services allegedly rendered by Dr.

Does Medicare pay for incident to billing?

The regulations state that Medicare will pay (100% of the physician fee schedule) for services and supplies that meet the following conditions: Services and supplies must be furnished in a noninstitutional setting ...

Can a nurse practitioner bill for incident to?

This means that a nurse practitioner or physician assistant cannot bill “incident to” if the service is not either in the course of the diagnosis that the physician made or if the service is not in the course of treatment by the physician. This requirement creates serious issues for practices and organizations because if a patient visits ...

Did Michael Fox bill his NPI?

Specifically, Dr. Michael Fox was alleged to have billed under his NPI for the services even though the “incident to” requirements had not been met. The government claimed that the physician involvement was minimal in that the “incident to” provisions would not apply. The physician and the practice resolved the allegations by settling for nearly $100,000.

What is incident to services?

Note: “Incident to” services are also relevant to services supervised by certain non-physician practitioners such as physician assistants, nurse practitioners, clinical nurse specialists, nurse midwives, or clinical psychologists. These services are subject to the same requirements as physician-supervised services. Remember that “incident services” supervised by non-physician practitioners are reimbursed at 85 percent of the physician fee schedule. For clarity’s sake, this article will refer to “physician” services as inclusive of non-physician practitioners.

Can an incident to billing be confusing?

Incident-to billing can be confusing. Unfortunately, many NPs find their employers want to bill under incident-to, yet there is often a mis-understanding of this issue, as we’ve t alked about before. The problem is it can potentially result in fraud charges if the rules are not followed.

When do hospitals report Medicare beneficiaries?

If the beneficiary is a dependent under his/her spouse's group health insurance and the spouse retired prior to the beneficiary's Medicare Part A entitlement date, hospitals report the beneficiary's Medicare entitlement date as his/her retirement date.

What is secondary payer?

Medicare is the Secondary Payer when Beneficiaries are: 1 Treated for a work-related injury or illness. Medicare may pay conditionally for services received for a work-related illness or injury in cases where payment from the state workers’ compensation (WC) insurance is not expected within 120 days. This conditional payment is subject to recovery by Medicare after a WC settlement has been reached. If WC denies a claim or a portion of a claim, the claim can be filed with Medicare for consideration of payment. 2 Treated for an illness or injury caused by an accident, and liability and/or no-fault insurance will cover the medical expenses as the primary payer. 3 Covered under their own employer’s or a spouse’s employer’s group health plan (GHP). 4 Disabled with coverage under a large group health plan (LGHP). 5 Afflicted with permanent kidney failure (End-Stage Renal Disease) and are within the 30-month coordination period. See ESRD link in the Related Links section below for more information. Note: For more information on when Medicare is the Secondary Payer, click the Medicare Secondary Payer link in the Related Links section below.

Does Medicare pay for black lung?

Federal Black Lung Benefits - Medicare does not pay for services covered under the Federal Black Lung Program. However, if a Medicare-eligible patient has an illness or injury not related to black lung, the patient may submit a claim to Medicare. For further information, contact the Federal Black Lung Program at 1-800-638-7072.

Does Medicare pay for the same services as the VA?

Veteran’s Administration (VA) Benefits - Medicare does not pay for the same services covered by VA benefits.

Is Medicare a primary or secondary payer?

Providers must determine if Medicare is the primary or secondary payer; therefore, the beneficiary must be queried about other possible coverage that may be primary to Medicare. Failure to maintain a system of identifying other payers is viewed as a violation of the provider agreement with Medicare.

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