Revenue Cycle Insider

Question: A physician and several nurses in our primary care practice occasionally travel as a team to see patients in a local skilled nursing facility. Can I bill incident-to services for the nurses and nurse practitioners (NPs) when they’re there at the same time?

Codify Subscriber

Answer: While you should check with the specific payer, providing sufficient documentation to show that incident-to criteria were met in such a setting could be tough.

Medicare Administrative Contractor (MAC) Noridian says: “Certain services may be covered under the ‘incident to’ provision when provided in the setting by auxiliary personnel employed by the physician/nonphysician practitioner and working under his/her direct supervision. However, many of these same services may not be covered when they are provided to hospital patients or nursing facility residents because the services do not ordinarily require performance by a physician and they are typically provided by personnel who are not employed by the physician and/or under his/her supervision in the hospital or nursing facility settings. Services such as therapeutic injections, breathing treatments and chemotherapy administration fall into this category.”

In her AAPC AUDITCON 2025 presentation “Incident To and Split/Shared Services,” Christine Hall, CPC, CDEO, CPB, CPMA, CRC, CPC-I, CEMC, gave explicit guidance, saying, “Incident-to doesn’t exist in the hospital or the nursing home or any institution. [Nurse practitioners] can go and see patients, but we bill it under the NP’s NPI [national provider identifier] number.”

Rachel Dorrell, MA, MS, CPC-A, Production Editor, AAPC