Practice Management Alert

Question: Is there any circumstance in which a group can bill all services and all providers (including other physicians) under just the medical director? I know we can bill NPP services incident-to another physician, but what about other physicians?

Colorado Subscriber

Answer: No, you cannot always bill services for all providers under a group's medical director. One reason is because you may not bill one doctor incident to another doctor. Incident-to rules don't apply here because they pertain to the relationship between a physician and a nonphysician practitioner (NPP), and in some instances both providers involved are physicians.

Bottom line: It is never acceptable to bill services provided by one physician under another physician's name or national provider identifier (NPI). Billing under the name of a physician who did not perform the service could lead to allegations of false claims submissions.

You can, however, report NPP services incident-to the medical director if the visits meet all the requirements of incident-to services. The NPP could be a physician assistant (PA), nurse practitioner (NP), or clinical nurse specialist -- as long as the NPP meets state and federal guidelines to provide the service. The NPP must be "licensed by the state under various programs to assist or act in the place of the physician," according to the Medicare Benefit Policy Manual, Chapter 15.

Best bet: Check your state and local Medicare regulations for NPP qualifications. If the NPP does not meet one or both sets of guidelines, don't bill incident-to for physician-level services (such as 99212-99215, Office or other outpatient visit ...).

Keep in mind: In order to bill the service under the medical director's NPI, there has to be a plan of care for the patient's condition (and the plan of care may have been developed by the patient's regular physician and not necessarily the medical director). Plus, the medical director must be physically on site in the office suite when the NPP is providing the service you are billing.