Incident to Provider Cannot Change Plan of Care

Incident to Provider Cannot Change Plan of Care

When a non-physician practitioner (NPP) performs an incident to service, that NPP must follow the plan of care as prescribed. He or she may not independently change the course of treatment. This requirement appears in Chapter 15, Section 60 of the Medicare Benefit Policy Manual, as shown in bold text:

… to have …[a] service covered as incident to the services of a physician, it must be performed under the direct supervision of the physician as an integral part of the physician’s personal in-office service. As explained in §60.1, this does not mean that each occasion of an incidental service performed by a nonphysician practitioner must always be the occasion of a service actually rendered by the physician. It does mean that there must have been a direct, personal, professional service furnished by the physician to initiate the course of treatment of which the service being performed by the nonphysician practitioner is an incidental part, and there must be subsequent services by the physician of a frequency that reflects the physician’s continuing active participation in and management of the course of treatment. In addition, the physician must be physically present in the same office suite and be immediately available to render assistance if that becomes necessary.

There may be changes in the course of treatment, over time, but a physician (not the nonphysician practitioner billing incident to) is required to make those changes.

John Verhovshek
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About Has 576 Posts

John Verhovshek, MA, CPC, is a contributing editor at AAPC. He has been covering medical coding and billing, healthcare policy, and the business of medicine since 1999. He is an alumnus of York College of Pennsylvania and Clemson University.

5 Responses to “Incident to Provider Cannot Change Plan of Care”

  1. melinda says:

    Can Audiologist bill insident to the provider because they dont have contracts with the insurance carriers

  2. Dena says:

    When billing incident to does the supervising physician and the P.A./CRNP need to be the same speciality? For example if the supervising Physician is a Neurologist and the P.A./CRNP is a practicing pain management does incident to apply?

  3. Dena says:

    When billing incident to does the physician and the PA/CRNP need to be the same specialty? For example when billing incident to can a neurologist be the supervising physician for a PA/CRNP performing pain management services?

  4. Caroline says:

    Melinda – Audiology Services have their own benefit category, and therefore, may not be reported as Incident-to services. cTw

  5. Samuel Cyril says:

    Does incident to apply when a NPP sees a patient. with physician in office, and a change of medication for the same diagnosis is given. Example, If PA sees a pt who is on Flomax for BPH and pt complains of side effect and is changed to Uroxatral for BPH. Medication is in same class for same diagnosis.