March 15, 2018

Question:
Our physician performed an evaluation on a patient and made a decision to start the patient on a series of Hyaluronate injections. The patient returned a week later because we had to order the drug.  Our PA saw the patient and administered the first injection of the series. Is this visit by the PA billed Incident-To the physician or must the PA direct bill to Medicare.

Answer:
The answer is dependent on whether or not a supervising physician is in the office. If yes, Incident-To rules are met as the plan of care was established the physician at the prior visit and the PA is now implementing the plan of care. If a supervising physician is not in the office, the PA must bill under the PA’s NPI as Incident-To rules are not met.

*This response is based on the best information available as of 03/15/18.