Practice Management Alert

Question: If our physician and nonphysician practitioner (NPP) are in contact over the phone — but are in different buildings — can our practice still bill “incident-to” on Medicare claims?

Iowa Subscriber

Answer: No. The Centers for Medicare & Medicaid Services (CMS) stipulates an NPP must be working under “direct supervision” of a physician to bill incident-to. The supervising physician cannot be across the street, three blocks away, or available via cell phone. If there is no physician physically present in the office suite during the time of the NPP service, the service must be billed to Medicare under the NPP’s name and National Provider Identifier (NPI).

Breakdown: According to Medicare’s direct supervision guidelines, the supervising physician:

• Must be physically present in the office suite.
• Need not be physically present in the treatment room.
• Must be readily available to provide assistance and direction to the NPP.
• Need not actually see the patient.