July 11, 2019

Question:
Our physicians have instructed us to bill under a physician’s NPI number for all Advanced Practitioners (PAs and NPs) for all patients for Medicare as we follow incident-to billing.  We have been submitting claims for all new and established patient visits regardless of whether there is a physician in the office.  I don’t think we are doing this right.  Can you help?

Answer:
In order to bill “Incident-to” a physician must be In the office suite immediately available. For new patients and established patients whose condition is new or worsening the encounter cannot be billed Incident-to the physician.  If the PA or NP is the only one to see the patient, it should be billed under the advanced practitioner’s NPI number.  You may bill incident-to for an established patient with an established care plan who is stable and does not have any new or worsening problems.  A physician should see all new patients and develop the care plan to qualify for incident to for routine follow- up visits.

*This response is based on the best information available as of 07/11/19.